Cambridge Research & Dev. Group v. Commissioner
United States Tax Court
L and K were the general partners of a limited partnership during 1983. K resigned as general partner in 1984 and converted his interest in the partnership to that of a limited partner.
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L and K were the general partners of a limited partnership during 1983. K resigned as general partner in 1984 and converted his interest in the partnership to that of a limited partner. In 1986, L signed, on behalf of all partners, a Form 872-O consent to extend the period for assessing tax attributable to partnership items for 1983. L had authority under Connecticut law and a written partnership agreement to bind the partnership and its partners through execution of instruments. However, no separate writing specifically authorizing L to extend the period of limitations existed. Held: K, the…
1Opinion of the Court
CAMBRIDGE RESEARCH AND DEVELOPMENT GROUP, KENNETH N. SHERMAN, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cambridge Research & Dev. Group v. Commissioner
Docket No. 3435-88
United States Tax Court
97 T.C. 287; 1991 U.S. Tax Ct. LEXIS 78; 97 T.C. No. 19;
September 5, 1991, Filed
L and K were the general partners of a limited partnership during 1983. K resigned as general partner in 1984 and converted his interest in the partnership to that of a limited partner. In 1986, L signed, on behalf of all partners, a Form 872-O consent to extend the period for assessing…
2Cases cited5 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Amesbury Apartments, Ltd. v. CommissionerUnited States Tax Court · 1990
- Barbados 7 Ltd. v. CommmmissionerUnited States Tax Court · 1989
- Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1991
- Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1989