Gmelin v. Commissioner
United States Tax Court
Petitioners invested $ 120,000 in three partnerships in 1978. On their Federal income tax return for 1978, petitioners deducted $ 478,389 as their distributive share of losses of the three partnerships in issue. Prior to the expiration of the statute of limitations with respect to petitioners' 1978 tax year, respondent audited the three partnerships in issue and proposed adjustments.
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Petitioners invested $ 120,000 in three partnerships in 1978. On their Federal income tax return for 1978, petitioners deducted $ 478,389 as their distributive share of losses of the three partnerships in issue. Prior to the expiration of the statute of limitations with respect to petitioners' 1978 tax year, respondent audited the three partnerships in issue and proposed adjustments. However, respondent allowed the statute of limitations to expire as to petitioners' 1978 year. Respondent thereafter issued a notice of deficiency as to petitioners' 1979 and 1980 years, determining that…
1Opinion of the Court
LENZ W. GMELIN AND INGEBORG U. GMELIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gmelin v. Commissioner
Docket Nos. 3673-85, 3831-85.1
United States Tax Court
T.C. Memo 1988-338; 1988 Tax Ct. Memo LEXIS 366; 55 T.C.M. (CCH) 1410; T.C.M. (RIA) 88338;
July 29, 1988.
Petitioners invested $ 120,000 in three partnerships in 1978. On their Federal income tax return for 1978, petitioners deducted $ 478,389 as their distributive share of losses of the three partnerships in issue. Prior to the expiration of the statute of limitations with respect to petitioners' 1978 tax year, respondent…
2Cases cited62 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Crane v. CommissionerSupreme Court of the United States · 1947
- Brown v. HelveringSupreme Court of the United States · 1934
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
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3Cited by1 opinion
- Richard L. Jones, and Margaret A. Jones v. United StatesCourt of Appeals for the Fifth Circuit · 1989