Meruelo v. Comm'r
United States Tax Court
R issued Ps a notice of deficiency (NOD) for 1999 that contained determinations related to an entity subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub.
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R issued Ps a notice of deficiency (NOD) for 1999 that contained determinations related to an entity subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 401, 96 Stat. 648. On their 1999 Federal income tax return, Ps claimed a deduction for a $ 4,538,844 loss that reportedly passed through to them from a partnership they identified as M. M was actually P-H's single-member limited liability company (LLC) that was a disregarded entity for Federal tax purposes; the claimed loss actually stemmed from IV, a…
1Opinion of the Court
OPINION
Vasquez, Judge:
Petitioners move the Court to dismiss this case for lack of jurisdiction. Petitioners petitioned the Court to redetermine respondent’s determination of a $1,581,293 deficiency in petitioners’ Federal income tax for 1999 and a $632,517 accuracy-related penalty under section 6662(h) (or alternatively a lesser accuracy-related penalty under section 6662(a)).1 Respondent included that determination in a notice of deficiency (nod) that reflects respondent’s disallowance of a $4,538,844 loss that petitioners claimed as a deduction. The loss stemmed from petitioner Alex…
2Cases cited17 opinions
- Adams v. JohnsonCourt of Appeals for the Ninth Circuit · 2004
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Jack Randell v. United StatesCourt of Appeals for the Second Circuit · 1995
12 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Meruelo v. CommissionerCourt of Appeals for the Ninth Circuit · 2012
- Maines v. Comm'rUnited States Tax Court · 2015
- Alex and Liset Meruelo v. CommissionerUnited States Tax Court · 2009
- David J. Maines & Tami L. Maines v. CommissionerUnited States Tax Court · 2015
5 more not listed; retrieve them via the Exa API.