G-5 Inv. P'ship v. Comm'r
United States Tax Court
G-5 filed its partnership return for 2000 on Oct. 4, 2001. R issued a notice of final partnership administrative adjustment (FPAA) to G-5 for 2000 on Apr. 12, 2006, more than 3 years after the date of filing of the partnership tax return and the filing of the partners' individual 2000 and 2001 Federal income tax returns, but before the expiration of 3 years from the dates the partners filed their individual 2002-04 Federal income tax returns.
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G-5 filed its partnership return for 2000 on Oct. 4, 2001. R issued a notice of final partnership administrative adjustment (FPAA) to G-5 for 2000 on Apr. 12, 2006, more than 3 years after the date of filing of the partnership tax return and the filing of the partners' individual 2000 and 2001 Federal income tax returns, but before the expiration of 3 years from the dates the partners filed their individual 2002-04 Federal income tax returns. R's FPAA denied partnership losses in 2000. G-5's partners reported their distributive shares of partnership losses for 2000 as capital loss carryovers…
1Opinion of the Court
OPINION
Haines, Judge:
This case is a partnership-level action based on a petition filed pursuant to section 6226.1 The sole issue raised by petitioners’ motion for judgment on the pleadings is whether the period of limitations for making assessments of income tax against individual partners, relative to partnership items, has expired pursuant to sections 6501 and 6229.
The following facts are based upon the parties’ pleadings. See Rule 120. They are stated solely for the purpose of deciding the motion for judgment on the pleadings and not as findings of fact in this case. See Fed. R. Civ. P.…
2Cases cited17 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Abrams v. CommissionerUnited States Tax Court · 1984
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Kligfeld Holdings v. Comm'rUnited States Tax Court · 2007
- White v. CommissionerUnited States Tax Court · 1990
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- Russian Recovery Fund Ltd. v. United StatesUnited States Court of Federal Claims · 2011
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