Bedrosian v. Comm'r
United States Tax Court
Ps invested in a Son-of-BOSS transaction through a partnership that was subject to the partnership provisions of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648. R issued an FPAA with respect to the partnership determining that the partnership was a sham. Ps did not file a timely petition. Ps claimed deductions for professional fees.
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Ps invested in a Son-of-BOSS transaction through a partnership that was subject to the partnership provisions of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648. R issued an FPAA with respect to the partnership determining that the partnership was a sham. Ps did not file a timely petition. Ps claimed deductions for professional fees. R issued a notice of deficiency duplicating the partnership adjustments and also disallowing the deduction for professional fees. R filed a motion to dismiss asserting that we lack jurisdiction over the…
1Opinion of the Court
OPINION
Buch, Judge:
This case has a long history, only the relevant portion of which we recount. For more background, see our prior opinions in this case, Bedrosian v. Commissioner, 143 T.C. 83 (2014), and T.C. Memo. 2007-375. See also Stone Canyon Partners v. Commissioner, T.C. Memo. 2007-377, aff’d sub nom. Bedrosian v. Commissioner, 358 Fed. Appx. 868 (9th Cir. 2009); Bedrosian v. Commissioner, T.C. Memo. 2007-376, aff’d, 358 Fed. Appx. 868 (9th Cir. 2009).
Background
The Bedrosians participated in what has come to be known as a Son-of-BOSS transaction, and that transaction involved an…
2Cases cited19 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Petaluma FX Partners, LLC v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2010
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3Cited by5 opinions
- John Finnegan v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2019
- Guralnik v. Comm'rUnited States Tax Court · 2016
- Bedrosian v. Comm'rUnited States Tax Court · 2015
- Laurence Gluck & Sandra Prusock v. CommissionerUnited States Tax Court · 2020
- Malone v. Comm'rUnited States Tax Court · 2017