AHG Invs., LLC v. Comm'r
United States Tax Court
R issued a notice of final partnership administrative adjustment (FPAA) determining adjustments to income on multiple grounds. The FPAA also determined an I.R.C. sec. 6662 40% gross valuation misstatement penalty, as well as other penalties.
Read the full summary
R issued a notice of final partnership administrative adjustment (FPAA) determining adjustments to income on multiple grounds. The FPAA also determined an I.R.C. sec. 6662 40% gross valuation misstatement penalty, as well as other penalties. P conceded the adjustments to income on grounds other than valuation or basis in an attempt to avoid the gross valuation misstatement penalty and filed a motion for partial summary judgment that this penalty does not apply as a matter of law. Held: A taxpayer may not avoid application of the gross valuation misstatement penalty merely by conceding on…
1Opinion of the Court
AHG INVESTMENTS, LLC, ALAN GINSBURG, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
AHG Invs., LLC v. Comm'r
Docket No. 3745-09.
United States Tax Court
140 T.C. 73; 2013 U.S. Tax Ct. LEXIS 7; 140 T.C. No. 7;
March 14, 2013, Filed
An appropriate order will be issued denying petitioner's motion for partial summary judgment.
R issued a notice of final partnership administrative adjustment (FPAA) determining adjustments to income on multiple grounds. The FPAA also determined an I.R.C. sec. 6662 40% gross valuation misstatement penalty, as well…
2Cases cited27 opinions
- Vasquez v. HillerySupreme Court of the United States · 1986
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Burnet v. Coronado Oil & Gas Co.Supreme Court of the United States · 1932
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
22 more not listed; retrieve them via the Exa API.