Thompson v. Commissioner
United States Tax Court
On the basis of a final decision in a partnership-level proceeding for RJT Investments X, LLC, which had made all partnership allocations for its tax year ended Dec. 31, 2001, to P-H, R determined an income tax deficiency and an accuracy-related penalty for Ps' 2001 tax year. Immediately after issuing a notice of deficiency to Ps, R directly assessed the deficiency and penalty amounts determined in that notice.
Read the full summary
On the basis of a final decision in a partnership-level proceeding for RJT Investments X, LLC, which had made all partnership allocations for its tax year ended Dec. 31, 2001, to P-H, R determined an income tax deficiency and an accuracy-related penalty for Ps' 2001 tax year. Immediately after issuing a notice of deficiency to Ps, R directly assessed the deficiency and penalty amounts determined in that notice. R has since acknowledged errors in these deficiency and penalty amounts and has made corresponding assessment abatements. Nonetheless, R argues that the notice of deficiency is invalid…
1Opinion of the Court
RANDALL J. AND KAREN G. THOMPSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Thompson v. Comm'r
Docket No. 30586-08.
United States Tax Court
137 T.C. 220; 2011 U.S. Tax Ct. LEXIS 50; 137 T.C. No. 17;
December 27, 2011, Filed
RJT Invs. X v. Commissioner, 491 F.3d 732, 2007 U.S. App. LEXIS 15738 (8th Cir., 2007)
An order of dismissal for lack of jurisdiction will be entered.
On the basis of a final decision in a partnership-level proceeding for RJT Investments X, LLC, which had made all partnership allocations for its tax year ended Dec. 31, 2001, to P-H, R determined an income tax…
Also in this document: Concurrence; Dissent · Goeke; Dissent · Holmes.
2Cases cited85 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Arbaugh v. Y & H Corp.Supreme Court of the United States · 2006
- Montana v. United StatesSupreme Court of the United States · 1979
- United States v. CottonSupreme Court of the United States · 2002
- Commissioner v. BrownSupreme Court of the United States · 1965
80 more not listed; retrieve them via the Exa API.