Aufleger v. Commissioner
United States Tax Court
On June 6, 1985, J, an S corporation, filed its corporate return for 1984. On March 2, 1987, R mailed notice of the final S corporation administrative adjustment (FSAA) to J's tax matters person. On March 3, 1987, R mailed notice of the FSAA to all J's notice shareholders except A. The tax matters person and the other notice shareholders did not seek timely judicial review of the FSAA.
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On June 6, 1985, J, an S corporation, filed its corporate return for 1984. On March 2, 1987, R mailed notice of the final S corporation administrative adjustment (FSAA) to J's tax matters person. On March 3, 1987, R mailed notice of the FSAA to all J's notice shareholders except A. The tax matters person and the other notice shareholders did not seek timely judicial review of the FSAA. On June 29, 1989, R mailed notice of the FSAA to A, and A did not elect to have the FSAA apply to him. On June 7, 1990, R mailed the notice of deficiency to A and A's wife. Held, when R mailed notice of the…
1Opinion of the Court
William E. Aufleger and Ada A. Aufleger, Petitioners v. Commissioner of Internal Revenue, Respondent
Aufleger v. Commissioner
Docket No. 19833-90
United States Tax Court
99 T.C. 109; 1992 U.S. Tax Ct. LEXIS 57; 99 T.C. No. 5;
July 23, 1992, Filed
Decision will be entered under Rule 155.
On June 6, 1985, J, an S corporation, filed its corporate return for 1984. On March 2, 1987, R mailed notice of the final S corporation administrative adjustment (FSAA) to J's tax matters person. On March 3, 1987, R mailed notice of the FSAA to all J's notice shareholders except A. The tax matters person and the…
2Cases cited14 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Fehlhaber v. CommissionerUnited States Tax Court · 1990
- Robert Fehlhaber v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1992
- Olds & Whipple, Inc. v. United StatesUnited States Court of Claims · 1938
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