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.
Read the full summary
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
OPINION
Jacobs, Judge:
Respondent determined a deficiency of $11,502.58 in petitioners’ 1984 Federal income taxes. On their 1984 individual income tax return, petitioners reported a loss of $18,172 as the distributive share of the loss of William E. Aufleger (referred to in the singular as petitioner) from Jokers, King of Comedy, Inc. (Jokers), an S corporation. Respondent determined that Jokers had a gain, not a loss, and that petitioner’s distributive share of the gain was $39,339.88, which resulted in an income adjustment of $57,511.88. After concessions by both parties, they now agree that…
2Cases cited13 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
8 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Boyd v. CommissionerUnited States Tax Court · 1993
- Miller v. CommissionerUnited States Tax Court · 1995
- Aufleger v. CommissionerUnited States Tax Court · 1992
- Boyd v. CommissionerUnited States Tax Court · 1993
- McElroy v. Comm'rUnited States Tax Court · 2014
2 more not listed; retrieve them via the Exa API.