1983 Western Reserve Oil & Gas Co. v. Commissioner
United States Tax Court
WROG and 1983 WROG are limited partnerships. The tax matters partner, P, disappeared in 1985 when a warrant was issued for his arrest. In February 1986, the two limited partnerships were placed in receivership and S was appointed receiver pendente lite by the U.S. District Court. S was not a partner in WROG or 1983 WROG.
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WROG and 1983 WROG are limited partnerships. The tax matters partner, P, disappeared in 1985 when a warrant was issued for his arrest. In February 1986, the two limited partnerships were placed in receivership and S was appointed receiver pendente lite by the U.S. District Court. S was not a partner in WROG or 1983 WROG. Creditors of WROG and 1983 WROG instituted involuntary bankruptcy proceedings against the two partnerships in May 1986. In September 1987, the receivership was terminated and the proceedings were referred to the bankruptcy court by the U.S. District Court. Notices of final…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
These cases were assigned to and heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A and Rule 180. All section references are to the Internal Revenue Code, unless otherwise stated, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge: These cases are before the Court on cross-motions to dismiss for lack of jurisdiction and are consolidated solely for…
2Cases cited22 opinions
- Burns, Stix Friedman & Co. v. CommissionerUnited States Tax Court · 1971
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Computer Programs Lambda, Ltd. v. CommissionerUnited States Tax Court · 1987
- Medeiros v. CommissionerUnited States Tax Court · 1981
- Liberty Nat. Bank of Roanoke, Va. v. BearSupreme Court of the United States · 1928
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- Montana Sapphire Assoc., Ltd. v. CommissionerUnited States Tax Court · 1990
- People Place Auto Hand Carwash, LLC v. Comm'rUnited States Tax Court · 2006
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