Woody v. Commissioner
United States Tax Court
In partnership administrative proceedings, R made adjustments to ordinary income of two partnerships in which P was one of two general partners. R also determined the amount of "guaranteed payments to general partner" and subsequently adjusted P's income to include the full amount of guaranteed payments.
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In partnership administrative proceedings, R made adjustments to ordinary income of two partnerships in which P was one of two general partners. R also determined the amount of "guaranteed payments to general partner" and subsequently adjusted P's income to include the full amount of guaranteed payments. R sent to P notices of deficiency determining only additions to tax under I.R.C. sec. 6661. P claims an overpayment based on allocation to him of the full amount of guaranteed payments, failure to credit amounts paid over to others, and failure to credit amounts previously reported on P's…
1Opinion of the Court
OPINION
COHEN, Judge:
These cases are before us on respondent’s motions to dismiss for lack of jurisdiction and to strike, directed at certain issues raised in the petitions. Respondent contends that we lack jurisdiction of those issues because of prior partnership proceedings conducted and settled administratively under sections 6221-6231, added by the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 324 (TEFRA provisions). Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the years in issue.
Petitioner was…
2Cases cited6 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Dial USA, Inc. v. CommissionerUnited States Tax Court · 1990
- Saso v. CommissionerUnited States Tax Court · 1989
- Munro v. CommissionerUnited States Tax Court · 1989
1 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- ESTATE OF QUICK v. COMMISSIONERUnited States Tax Court · 1998
- Harris v. CommissionerUnited States Tax Court · 1992
- Olson v. United StatesCourt of Appeals for the Federal Circuit · 1999
- Bradley v. CommissionerUnited States Tax Court · 1993
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