Legal Opinion

AHG Invs., LLC v. Comm'r

United States Tax Court

Decided March 14, 2013No. Docket No. 3745-09Published

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.

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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

  1. Vasquez v. HillerySupreme Court of the United States · 1986
  2. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  3. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  4. Burnet v. Coronado Oil & Gas Co.Supreme Court of the United States · 1932
  5. Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988

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