Avedisian v. Commissioner
United States Tax Court
Ps purchased certain ranch property in 1979 from S. Ps and S reported on their respective tax returns inconsistent allocations of the purchase price among depreciable and nondepreciable components of the property. R issued notices of deficiency to both Ps and S, taking inconsistent positions by adjusting the allocation claimed by each.
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Ps purchased certain ranch property in 1979 from S. Ps and S reported on their respective tax returns inconsistent allocations of the purchase price among depreciable and nondepreciable components of the property. R issued notices of deficiency to both Ps and S, taking inconsistent positions by adjusting the allocation claimed by each. The notices of deficiency issued to Ps adopted the allocation as reported by S. Ps filed a Motion to Compel the Production of Documents seeking income tax returns and tax return information of S. Held, Ps' Motion to Compel is denied since the information sought…
1Opinion of the Court
ALFRED M. AVEDISIAN AND ALICE B. AVEDISIAN, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Avedisian v. Commissioner
Docket Nos. 2050-85, 3630-85.
United States Tax Court
T.C. Memo 1987-176; 1987 Tax Ct. Memo LEXIS 175; 53 T.C.M. (CCH) 503; T.C.M. (RIA) 87176;
March 31, 1987.
Ps purchased certain ranch property in 1979 from S. Ps and S reported on their respective tax returns inconsistent allocations of the purchase price among depreciable and nondepreciable components of the property. R issued notices of deficiency to both Ps and S, taking inconsistent positions by adjusting the…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Jackson v. CommissionerUnited States Tax Court · 1979
- International Business MacHines Corporation v. The United StatesUnited States Court of Claims · 1965
- William O'Dwyer and Sloan O'Dwyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
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