Modern Computer Games, Inc. v. Commissioner
United States Tax Court
P petitioned this Court as tax matters person (TMP) of Games, an S corporation, and moved for summary judgment on the ground that the notice of final S corporation administrative adjustment (FSAA) was mailed by R after the expiration of the statutory period of limitations. Games had never formally designated a tax matters person.
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P petitioned this Court as tax matters person (TMP) of Games, an S corporation, and moved for summary judgment on the ground that the notice of final S corporation administrative adjustment (FSAA) was mailed by R after the expiration of the statutory period of limitations. Games had never formally designated a tax matters person. Prior to the expiration of the limitations period and to the mailing of the FSAA, a consent agreement to extend the limitations period was executed by shareholder L, as TMP. L held the largest profits interest in Games. No person had been designated TMP by Games.…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This case was assigned to Special Trial Judge Buckley pursuant to the provisions of section TJJSAib).1 After a review of the record, we agree with and adopt her opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
BUCKLEY, Special Trial Judge: This matter is before us on petitioner’s motion for summary judgment under Rule 121. Petitioner, the tax matters person of Modern Computer Games, Inc. (Games), a subchapter S corporation, contends that the statutory period of limitations bars respondent’s determination of adjustments to Games’ 1983 S corporation…
2Cases cited4 opinions
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Chomp Assoc. v. CommissionerUnited States Tax Court · 1988
- Gold-N-Travel, Inc. v. CommissionerUnited States Tax Court · 1989
- Modern Computer Games, Inc. v. CommissionerUnited States Tax Court · 1989
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- Modern Computer Games, Inc. v. CommissionerUnited States Tax Court · 1991