Kennedy v. Commissioner
United States Tax Court
Ps filed a motion for award of litigation costs. Ps are dairy farmers who used the cash method of accounting. R commenced a Taxpayer Compliance Measurement Program (TCMP) examination of Ps' dairy business activities and determined adjustments to income of Ps and Ps' partnerships which were based largely on R's change of the accounting method employed by Ps from the cash method to the accrual method.
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Ps filed a motion for award of litigation costs. Ps are dairy farmers who used the cash method of accounting. R commenced a Taxpayer Compliance Measurement Program (TCMP) examination of Ps' dairy business activities and determined adjustments to income of Ps and Ps' partnerships which were based largely on R's change of the accounting method employed by Ps from the cash method to the accrual method. After R issued notices of deficiency to Ps incorporating the TCMP determinations, these cases were settled by stipulation of the parties. The determinations agreed upon in the respective…
1Opinion of the Court
Roy C. Kennedy, Sr., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Kennedy v. Commissioner
Docket No. 4308-85, 4541-85, 4557-85, 4558-85, 5639-85
United States Tax Court
89 T.C. 98; 1987 U.S. Tax Ct. LEXIS 100; 89 T.C. No. 11;
July 16, 1987July 16, 1987, Filed
Ps filed a motion for award of litigation costs. Ps are dairy farmers who used the cash method of accounting. R commenced a Taxpayer Compliance Measurement Program (TCMP) examination of Ps' dairy business activities and determined adjustments to income of Ps and Ps' partnerships which were based largely on R's change…
2Cases cited16 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Minahan v. CommissionerUnited States Tax Court · 1987
- United States v. CattoSupreme Court of the United States · 1966
- Robert Randall Baker v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1986
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