Legal Opinion

Eastern States Casualty Agency, Inc. v. Commissioner

United States Tax Court

Decided June 4, 1991No. Docket No. 3497-90Published

R issued a notice of final S corporation administrative adjustment (FSAA) to E for its taxable year ending Dec. 31, 1984. E, an S corporation, had four shareholders during 1984. P, as tax matters person, filed a timely petition for readjustment and a motion to dismiss for lack of jurisdiction.

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R issued a notice of final S corporation administrative adjustment (FSAA) to E for its taxable year ending Dec. 31, 1984. E, an S corporation, had four shareholders during 1984. P, as tax matters person, filed a timely petition for readjustment and a motion to dismiss for lack of jurisdiction. P contends that the FSAA is invalid because S corporations with 10 or fewer shareholders are excepted from the unified audit and litigation procedures pursuant to I.R.C. sec. 6244 and 6231(a)(1)(B). Held, prior to the effective date of sec. 301.6241-1T(c), Temporary Proced. & Admin. Regs., no S…

1Opinion of the Court

Eastern States Casualty Agency, Inc., Wilma Smith, Tax Matters Person, Petitioner v. Commissioner of Internal Revunue, Respondent

Eastern States Casualty Agency, Inc. v. Commissioner

Docket No. 3497-90

United States Tax Court

96 T.C. 773; 1991 U.S. Tax Ct. LEXIS 42; 96 T.C. No. 35;

June 4, 1991, Filed

R issued a notice of final S corporation administrative adjustment (FSAA) to E for its taxable year ending Dec. 31, 1984. E, an S corporation, had four shareholders during 1984. P, as tax matters person, filed a timely petition for readjustment and a motion to dismiss for lack of jurisdiction. P…

Also in this document: Dissent.

2Cases cited13 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Maxwell v. CommissionerUnited States Tax Court · 1986
  3. N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
  4. United States v. PyneSupreme Court of the United States · 1941
  5. Saso v. CommissionerUnited States Tax Court · 1989

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