Cambridge Research & Dev. Group v. Commissioner
United States Tax Court
Petitioners moved to dismiss for lack of jurisdiction on grounds that the notice of final partnership administrative adjustment was invalid because it was issued after expiration of the period of limitations. Held, the timeliness of the notice of final partnership administrative adjustment is not relevant to the jurisdiction of the Court under section 6226, so petitioner's motion is denied.
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
T.C. Memo 1989-679; 1989 Tax Ct. Memo LEXIS 679; 58 T.C.M. (CCH) 1053; T.C.M. (RIA) 89679;
December 28, 1989
Petitioners moved to dismiss for lack of jurisdiction on grounds that the notice of final partnership administrative adjustment was invalid because it was issued after expiration of the period of limitations. Held, the timeliness of the notice of final…
2Cases cited4 opinions
- Pyo v. CommissionerUnited States Tax Court · 1984
- Abeles v. CommissionerUnited States Tax Court · 1988
- Robinson v. CommissionerUnited States Tax Court · 1972
- Mollet v. CommissionerUnited States Tax Court · 1984
3Cited by2 opinions
- Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1991
- Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1991