Legal Opinion
Laidlaw's Harley Davidson Sales, Inc. v. Commissioner
United States Tax Court
Decided January 16, 2020Unknown
1Opinion of the Court
154 T.C. No. 4
UNITED STATES TAX COURT LAIDLAW’S HARLEY DAVIDSON SALES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14616-14L. Filed January 16, 2020. The IRS determined that P, a C corporation, failed to timely disclose its participation in a listed transaction as required under I.R.C. sec. 6011 when it filed a Form 1120, “U.S. Corporation Income Tax Return”, for the tax year ending May 31, 2008. The revenue agent responsible for examining P’s May 2008 return issued a 30-day letter to P that proposed to assert a penalty under I.R.C. sec. 6707A against P for…
2Cases cited20 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Goza v. CommissionerUnited States Tax Court · 2000
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
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