PCMG Trading Ptnrs. XX, L.P. v. Comm'r
United States Tax Court
On Feb. 28, 2008, five indirect partners filed a petition pursuant to sec. 6226(b)(1), I.R.C., as members of a 5-percent group challenging adjustments to partnership items in the notice of final partnership administrative adjustment (FPAA) and asserting that the period of limitations on assessments had expired.
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On Feb. 28, 2008, five indirect partners filed a petition pursuant to sec. 6226(b)(1), I.R.C., as members of a 5-percent group challenging adjustments to partnership items in the notice of final partnership administrative adjustment (FPAA) and asserting that the period of limitations on assessments had expired. On Feb. 29, 2008, six petitions regarding the same FPAA were filed, one by the pass-thru partner through which the five indirect partners held their interests in the partnership and one by each of the same individual indirect partners who filed the initial petition on Feb. 28, 2008.…
1Opinion of the Court
OPINION
Ruwe, Judge:
These seven cases were consolidated for purposes of considering respondent’s motions to dismiss the six cases bearing docket Nos. 5149-08, 5150-08, 5151-08, 5152-OS, 5153-08, and 5154-08, for lack of jurisdiction pursuant to section 6226(b)(2) and (4).2
Background
On October 3, 2007, pursuant to section 6223(a)(2), respondent issued a notice of final partnership administrative adjustment (fpaa) to the Private Capital Management Group, L.L.C., the tax matters partner (TMP) for PCMG Trading Partners XX, L.P. (the partnership), for the taxable years 1999 and 2000.3 On the same…
2Cases cited12 opinions
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Jack Randell v. United StatesCourt of Appeals for the Second Circuit · 1995
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Brannon's of Shawnee, Inc. v. CommissionerUnited States Tax Court · 1978
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- Uviado, LLC ex rel. Khan v. United States ex rel. Internal Revenue ServiceDistrict Court, S.D. Texas · 2010
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