Legal Opinion
Salman Ranch Ltd. v. United States
United States Court of Federal Claims
Decided November 9, 2007No. 06-503TPublishedCited by 17 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
CHRISTINE O.C. MILLER, Judge.
This case is before the court after argument and supplemental briefing on cross-motions for summary judgment. Taxpayers assert that the statute of limitations set forth in 26 U.S.C. (“I.R.C.”) §§ 6501 and 6229 (2000), bars the Internal Revenue Service’s (the “IRS”) proposed adjustments to partnership items of Salman Ranch, Ltd., as reflected in the Final Partnership Administrative Adjustment, issued on April 10, 2006 for the partnership’s 1999 income-tax returns. The dispositive issue is whether the Final Partnership Administrative…
2Cases cited27 opinions
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Kligfeld Holdings v. Comm'rUnited States Tax Court · 2007
- Lima Surgical Associates, Inc., Voluntary Employees' Beneficiary Association Plan Trust, Huntington National Bank, Trustee v. The United StatesCourt of Appeals for the Federal Circuit · 1991
- First Commerce Corporation, and Fdic, Federal Deposit Insurance Corporation, and First Commerce Savings Bank v. United StatesCourt of Appeals for the First Circuit · 2003
- Colony, Inc. v. CommissionerUnited States Tax Court · 1956
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3Cited by17 opinions
- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
- Bakersfield Energy Partners, LP v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- Salman Ranch Ltd. v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Salman Ranch, Ltd. v. CommissionerCourt of Appeals for the Tenth Circuit · 2011
- Home Concrete & Supply, LLC v. United StatesCourt of Appeals for the Fourth Circuit · 2011
12 more not listed; retrieve them via the Exa API.