Lardas v. Commissioner
United States Tax Court
R determined deficiencies on account of the disallowance of losses deriving from Ps' interests in two grantor trusts. R's notices of deficiency were issued within the period for assessing deficiencies against Ps, but more than 3 years after the grantor trusts filed their respective information returns. At the times the deficiency notices were issued, no consent to extend the period for assessment against either trust was in effect.
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R determined deficiencies on account of the disallowance of losses deriving from Ps' interests in two grantor trusts. R's notices of deficiency were issued within the period for assessing deficiencies against Ps, but more than 3 years after the grantor trusts filed their respective information returns. At the times the deficiency notices were issued, no consent to extend the period for assessment against either trust was in effect. Held: R's notices of deficiency were timely issued. Sec. 6501(a), I.R.C., proscribing assessment after 3 years following the filing of "the return", refers to the…
1Opinion of the Court
John A. and Shirley R. Lardas, Petitioners v. Commissioner of Internal Revenue, Respondent; Angelo A. and Janet M. Lardas, Petitioners v. Commissioner of Internal Revenue, Respondent
Lardas v. Commissioner
Docket Nos. 29363-89, 30368-89
United States Tax Court
99 T.C. 490; 1992 U.S. Tax Ct. LEXIS 79; 99 T.C. No. 25;
October 22, 1992, Filed
Decisions will be entered under Rule 155.
R determined deficiencies on account of the disallowance of losses deriving from Ps' interests in two grantor trusts. R's notices of deficiency were issued within the period for assessing deficiencies against Ps, but more…
Also in this document: Dissent.
2Cases cited17 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Lawrence v. CommissionerUnited States Tax Court · 1957
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