InverWorld, Ltd. v. Commissioner
United States Tax Court
R issued two separate statutory notices (notice A and notice B) to P dated Sept. 7, 1990, relating to P's tax liability for 1984, 1985, and 1986. P timely filed a petition contesting R's determinations made in notice A. P attached to its petition notice A but not notice B. P did not specifically refer to notice B or dispute R's determinations contained therein in the petition.
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R issued two separate statutory notices (notice A and notice B) to P dated Sept. 7, 1990, relating to P's tax liability for 1984, 1985, and 1986. P timely filed a petition contesting R's determinations made in notice A. P attached to its petition notice A but not notice B. P did not specifically refer to notice B or dispute R's determinations contained therein in the petition. After the expiration of the period for filing a petition, P filed a motion for leave to file amendments to petition to contest the deficiencies and additions to tax determined in notice B. P and R agree that notice B…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This case is before the Court on petitioner's motion for leave to file amendments to petition filed pursuant to Rule 41(a). (All Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the years in issue.)
Background
Petitioner is a Cayman Island corporation with its registered office in Grand Cayman, B.W.I. On September 7, 1990, respondent issued two separate statutory notices to petitioner which relate to petitioner's tax liability for the years 1984,…
2Cases cited8 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- O'Neil v. CommissionerUnited States Tax Court · 1976
- Martz v. CommissionerUnited States Tax Court · 1981
- S-K Liquidating Co. v. CommissionerUnited States Tax Court · 1975
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3Cited by12 opinions
- Northern Ind. Pub. Serv. Co. v. CommissionerUnited States Tax Court · 1993
- Martin v. CommissionerCourt of Appeals for the Tenth Circuit · 2006
- Robinson v. Comm'rUnited States Tax Court · 2001
- Kanofsky v. Comm'rUnited States Tax Court · 2010
- InverWorld, Ltd. v. CommissionerUnited States Tax Court · 1992
7 more not listed; retrieve them via the Exa API.