Legal Opinion
Salman Ranch, Ltd. v. Commissioner
Court of Appeals for the Tenth Circuit
Decided May 31, 2011No. 09-9015PublishedCited by 36 opinions
1Opinion of the Court
SEYMOUR, Circuit Judge.
The Commissioner of the Internal Revenue Service appeals a decision of the Tax Court granting summary judgment in favor of Salman Ranch, Ltd. (“Partnership”), holding that the IRS’s administrative adjustments of the Partnership’s 2001 and 2002 tax returns were barred by the three-year limitations period in I.R.C. § 6501(a). We have jurisdiction pursuant to I.R.C. § 7482(a)(1). Because we conclude the IRS’s adjustments were timely under the six-year limitations period in I.R.C. § 6501(e)(1)(A), we reverse.
I
The Partnership owns a ranch in Mora County, New Mexico. This…
2Cases cited28 opinions
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- Allen v. McCurrySupreme Court of the United States · 1980
- Montana v. United StatesSupreme Court of the United States · 1979
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Commissioner v. SunnenSupreme Court of the United States · 1948
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