Mecom v. Commissioner
United States Tax Court
P filed timely his 1976 Federal income tax return on which he reported an $ 861,019 net operating loss (NOL) deduction arising from his distributive share of Nol's that the New Orleans Saints, a Louisiana partnership, passed through to him in prior years. In 1979, respondent began examining P's 1976 taxable year. In connection with respondent's examination, P signed six consents seriatim extending the 3-year period of limitation under sec. 6501(a), I.R.C.
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P filed timely his 1976 Federal income tax return on which he reported an $ 861,019 net operating loss (NOL) deduction arising from his distributive share of Nol's that the New Orleans Saints, a Louisiana partnership, passed through to him in prior years. In 1979, respondent began examining P's 1976 taxable year. In connection with respondent's examination, P signed six consents seriatim extending the 3-year period of limitation under sec. 6501(a), I.R.C. The sixth consent, Form 872-a, included language restricting any assessment for 1976 to adjustments resulting from, inter alia, "any…
1Opinion of the Court
Laro, Judge:
John W. Mecom, Jr., and Katsy Mecom petitioned this Court for a redetermination of respondent’s determination of a $413,686.75 deficiency in their 1976 Federal income tax. Although Katsy Mecom is a copetitioner, for simplicity and clarity, we refer to John W. Mecom, Jr., as petitioner. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1976, the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After stipulations by the parties, the issues for decision are: (1) Whether the consents…
2Cases cited46 opinions
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