Rawls Trading, L.P. v. Comm'r
United States Tax Court
R simultaneously issued notices of final partnership administrative adjustment (FPAAs) to two lower tier, or "source" partnerships, and one upper tier, or "interim" partnership. The FPAA issued to the interim partnership purports to give effect only to the adjustments shown on the FPAAs issued to the source partnerships. Ps petitioned the Court challenging all three FPAAs, and the three partnership proceedings were consolidated.
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R simultaneously issued notices of final partnership administrative adjustment (FPAAs) to two lower tier, or "source" partnerships, and one upper tier, or "interim" partnership. The FPAA issued to the interim partnership purports to give effect only to the adjustments shown on the FPAAs issued to the source partnerships. Ps petitioned the Court challenging all three FPAAs, and the three partnership proceedings were consolidated. R subsequently asked to stay the proceeding for the interim partnership, conceding that the underlying FPAA was issued prematurely but asserting that the FPAA is…
1Opinion of the Court
Vasquez, Judge:
These three consolidated cases are before the Court on respondent’s request to stay the proceeding in one case. The cases constitute partnership-level proceedings under the unified partnership audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (tefra), Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648 (codified as amended at sections 6221-6233).2
Once each during two discrete periods, the first spanning late March through early April 2000 and the other covering early August through early September 2000, Jerry S. Rawls engaged in the short sale…
2Cases cited15 opinions
- Arbaugh v. Y & H Corp.Supreme Court of the United States · 2006
- United States v. CottonSupreme Court of the United States · 2002
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Maxwell v. CommissionerUnited States Tax Court · 1986
10 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Bedrosian v. Comm'rUnited States Tax Court · 2014
- Bedrosian v. Comm'rUnited States Tax Court · 2014
- Bedrosian v. Comm'rUnited States Tax Court · 2014
- John C. Bedrosian & Judith D. Bedrosian v. CommissionerUnited States Tax Court · 2014
- John C. Bedrosian & Judith D. Bedrosian v. CommissionerUnited States Tax Court · 2014
3 more not listed; retrieve them via the Exa API.