Basr Partnership, by and Through, William F. Pettinati, Sr., Tax Matters Partner v. United States
United States Court of Federal Claims
1Opinion of the Court
REVISED MEMORANDUM OPINION AND FINAL ORDER
BRADEN, Judge.
This ease concerns a petition filed in the United States Court of Federal Claims, pursuant to 28 U.S.C. § 1508, for a readjustment and refund of federal taxes paid, plus interest. The pending motion for summary judgment requests that the court determine that the refund, plus interest, is due, because a January 20, 2010 Internal Revenue Service (“IRS”) Notice of Final Partnership Administrative Adjustment (“FPAA”) was time-barred by 26 U.S.C. § 6229(c)(1). In the alternative, the pending motion argues that the FPAA is timebarred, because…
2Cases cited32 opinions
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