Affiliated Equipment Leasing II v. Commissioner
United States Tax Court
Ps filed a motion to reconsider an order of this Court granting R's motion to dismiss as to I.R.C. sec. 6621(c) interest. Held, this Court lacks jurisdiction over I.R.C. sec. 6621(c) interest in a partnership level proceeding because I.R.C. sec. 6621(c) interest is an "affected item" which can only be determined, if at all, at the individual partner level.
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This matter is before the Court on petitioners’ motion to reconsider granting of respondent’s motion to dismiss for lack of jurisdiction and to strike with respect to section 6621(c), I.R.C., filed March 25, 1991. The issue for decision is whether the Court has jurisdiction to determine at the partnership level whether the adjustments made on the notices of final partnership administrative adjustment are attributable to a tax-motivated transaction pursuant to section 6621(c). (All section references are to sections of the Internal Revenue Code in effect for the years…
2Cases cited7 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Woods v. CommissionerUnited States Tax Court · 1989
- White v. CommissionerUnited States Tax Court · 1990
- Barton v. CommissionerUnited States Tax Court · 1991
2 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Hambrose Leasing 1984-5 Ltd. Partnership v. CommissionerUnited States Tax Court · 1992
- Harris v. CommissionerUnited States Tax Court · 1992
- Keener v. United StatesUnited States Court of Federal Claims · 2007
- Prati v. United StatesUnited States Court of Federal Claims · 2008
13 more not listed; retrieve them via the Exa API.