Legal Opinion

Cambridge Research & Dev. Group v. Commissioner

United States Tax Court

Decided December 28, 1989No. Docket No. 3435-88UnpublishedCited by 2 opinions

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

  1. Pyo v. CommissionerUnited States Tax Court · 1984
  2. Abeles v. CommissionerUnited States Tax Court · 1988
  3. Robinson v. CommissionerUnited States Tax Court · 1972
  4. Mollet v. CommissionerUnited States Tax Court · 1984

3Cited by2 opinions

  1. Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1991
  2. Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1991

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