Adkison v. Comm'r
United States Tax Court
R sent to P a notice of deficiency for 1999. P filed a petition seeking to invoke the Court's jurisdiction to redetermine the deficiency and to decide P's claim for relief under sec. 6015(c), I.R.C.
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R sent to P a notice of deficiency for 1999. P filed a petition seeking to invoke the Court's jurisdiction to redetermine the deficiency and to decide P's claim for relief under sec. 6015(c), I.R.C. R moved to dismiss for lack of jurisdiction on the grounds (1) the notice of deficiency is invalid because the underlying adjustments constitute "partnership items" that are the subject of an ongoing partnership-level proceeding in Federal District Court, and (2) P's claim for relief under sec. 6015(c), I.R.C., constitutes an "affected item" that can be reviewed only after the partnership-level…
1Opinion of the Court
OPINION
Cohen, Judge:
This case is before us on respondent’s motion to dismiss for lack of jurisdiction on the ground the notice of deficiency is invalid and prohibited by section 6225. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.
Background
The parties stipulated certain facts solely for our action on respondent’s motion to dismiss for lack of jurisdiction. Peter D. Adkison (petitioner) resided in Seattle, Washington, at the time that he filed his petition.
Petitioner filed a joint Federal income tax return for 1999 with his…
2Cases cited15 opinions
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Cheshire v. CommissionerUnited States Tax Court · 2000
- Kathryn Cheshire v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2002
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
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