Saso v. Commissioner
United States Tax Court
R issued notices of final partnership administrative adjustment (FPAAs) on Apr. 13, 1987, determining adjustments to the 1982 and 1983 partnership returns of Pepiot. No petition for readjustment of partnership items was filed in response to the FPAAs. After the period for filing a readjustment petition expired, R computed and assessed the tax owed by Ps, limited partners in Pepiot, for 1982 and 1983 pursuant to sec. 6225(c), I.R.C.
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R issued notices of final partnership administrative adjustment (FPAAs) on Apr. 13, 1987, determining adjustments to the 1982 and 1983 partnership returns of Pepiot. No petition for readjustment of partnership items was filed in response to the FPAAs. After the period for filing a readjustment petition expired, R computed and assessed the tax owed by Ps, limited partners in Pepiot, for 1982 and 1983 pursuant to sec. 6225(c), I.R.C. On Aug. 12, 1988, R issued a notice of deficiency to Ps determining additions to tax under secs. 6653(a)(1) and (2) and 6661(a), I.R.C., and additional interest…
1Opinion of the Court
WILLIAMS, Judge:
This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.1 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction and to strike.2 The issue for decision is whether petitioners may seek a redetermination of deficiencies attributable to partnership items in response to a notice of deficiency determining additions to tax subsequent…
2Cases cited9 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- King v. CommissionerUnited States Tax Court · 1987
4 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- White v. CommissionerUnited States Tax Court · 1990
- Crowell v. CommissionerUnited States Tax Court · 1994
- Powell v. CommissionerUnited States Tax Court · 1991
- Blonien v. Comm'rUnited States Tax Court · 2002
- Bradley v. CommissionerUnited States Tax Court · 1993
41 more not listed; retrieve them via the Exa API.