Powell v. Commissioner
United States Tax Court
Ps and R executed a settlement agreement resolving partnership items pertaining to the taxable years 1983 and 1984. Subsequently, R issued notices of deficiency to Ps determining additions to tax under I.R.C. sec. 6659 for the taxable years 1983 and 1984 and increased interest pursuant to I.R.C. sec. 6621(c). Ps filed timely petitions for redetermination disputing the additions to tax, the increased interest, and the tax attributable to the settlement of partnership items.
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Ps and R executed a settlement agreement resolving partnership items pertaining to the taxable years 1983 and 1984. Subsequently, R issued notices of deficiency to Ps determining additions to tax under I.R.C. sec. 6659 for the taxable years 1983 and 1984 and increased interest pursuant to I.R.C. sec. 6621(c). Ps filed timely petitions for redetermination disputing the additions to tax, the increased interest, and the tax attributable to the settlement of partnership items. R assessed both the tax attributable to the settlement of partnership items and increased interest under I.R.C. sec.…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
These cases are before the Court on petitioners’ motions to restrain assessment and collection. (Unless otherwise indicated, all section references are to sections of the Internal Revenue Code as in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure.)
Background
On November 9, 1988, respondent issued notices of final partnership administrative adjustment for the taxable years 1983 and 1984 to the tax matters partner (TMP) of Assets Trading Ltd., a partnership subject to partnership level proceedings pursuant to the…
2Cases cited6 opinions
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- White v. CommissionerUnited States Tax Court · 1990
- National Committee to Secure Justice, etc. v. CommissionerUnited States Tax Court · 1957
- Smith v. CommissionerUnited States Tax Court · 1991
- Saso v. CommissionerUnited States Tax Court · 1989
1 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Meyer v. CommissionerUnited States Tax Court · 1991
- Harris v. CommissionerUnited States Tax Court · 1992
- Bradley v. CommissionerUnited States Tax Court · 1993
- Powerstein v. CommissionerUnited States Tax Court · 1992
- Brookes v. CommissionerUnited States Tax Court · 1997
36 more not listed; retrieve them via the Exa API.