Crowell v. Commissioner
United States Tax Court
Ps were partners in a partnership, Wind 2, that is subject to the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, sec. 402(a), 96 Stat. 648. On Sept. 13, 1991, R mailed a notice of final partnership administrative adjustment (FPAA) for the 1983 and 1984 taxable years to the tax matters partner. On Oct. 13, 1991, R mailed a copy of the FPAA for the 1983 taxable year to Ps.
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Ps were partners in a partnership, Wind 2, that is subject to the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, sec. 402(a), 96 Stat. 648. On Sept. 13, 1991, R mailed a notice of final partnership administrative adjustment (FPAA) for the 1983 and 1984 taxable years to the tax matters partner. On Oct. 13, 1991, R mailed a copy of the FPAA for the 1983 taxable year to Ps. No petition for readjustment was filed with respect to the FPAA for either 1983 or 1984. After the time for filing such a petition expired, R assessed deficiencies in Ps' Federal income taxes for taxable…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 This Court agrees with and adopts the opinion of the Chief Special Trial Judge which is set forth below.
OPINION OF THE CHIEF SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge: This matter is before the Court on respondent’s motions, one filed on March 1, 1993, and the other on March 8, 1993, each seeking to dismiss for lack of jurisdiction and to strike a portion of the petition. The issues to be decided involve the scope of this Court’s…
2Cases cited11 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Monge v. CommissionerUnited States Tax Court · 1989
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- White v. CommissionerUnited States Tax Court · 1990
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- Keener v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Adkison v. CommissionerCourt of Appeals for the Ninth Circuit · 2010
- Keener v. United StatesUnited States Court of Federal Claims · 2007
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