McNeill v. Comm'r
United States Tax Court
For 2003 Ps filed jointly their Form 1040, claiming deductions for losses--reflected on a Schedule K-1--flowing from a tax shelter. R issued to the partnership an FPAA disallowing the loss deductions and asserting an accuracy-related penalty under I.R.C. sec. 6662. P-H, as the TMP of a partner other than the partnership's TMP, paid to R the tax liability and interest and instituted a partnership-level proceeding in District Court.
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For 2003 Ps filed jointly their Form 1040, claiming deductions for losses--reflected on a Schedule K-1--flowing from a tax shelter. R issued to the partnership an FPAA disallowing the loss deductions and asserting an accuracy-related penalty under I.R.C. sec. 6662. P-H, as the TMP of a partner other than the partnership's TMP, paid to R the tax liability and interest and instituted a partnership-level proceeding in District Court. The proceeding was dismissed without a ruling on Ps' partner-level defenses to the accuracy-related penalty under I.R.C. sec. 6662. R assessed the penalty and…
1Opinion of the Court
CORBIN A. MCNEILL AND DORICE S. MCNEILL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
McNeill v. Comm'r
Docket No. 14340-10L.
United States Tax Court
2017 U.S. Tax Ct. LEXIS 25; 148 T.C. No. 23;
June 19, 2017, Filed
Gramercy Advisors, LLC v. BDO USA, LLP, 2015 Conn. Super. LEXIS 823 (Conn. Super. Ct., Apr. 9, 2015)
For 2003 Ps filed jointly their Form 1040, claiming deductions for losses--reflected on a Schedule K-1--flowing from a tax shelter. R issued to the partnership an FPAA disallowing the loss deductions and asserting an accuracy-related penalty under I.R.C. sec. 6662. P-H, as…
2Cases cited19 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Naftel v. CommissionerUnited States Tax Court · 1985
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Montgomery v. Comm'rUnited States Tax Court · 2004
- Pyo v. CommissionerUnited States Tax Court · 1984
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