Columbia Bldg. v. Commissioner
United States Tax Court
In 1987, M, the sole general partner of C (a partnership subject to the unified audit and litigation procedures), filed a petition in bankruptcy. In 1988, R mailed a single notice of final partnership administrative adjustment (FPAA) addressed to M as tax matters partner (TMP) of C. Thereafter, R mailed the FPAA to notice partners, one of whom filed a timely petition for readjustment.
Read the full summary
In 1987, M, the sole general partner of C (a partnership subject to the unified audit and litigation procedures), filed a petition in bankruptcy. In 1988, R mailed a single notice of final partnership administrative adjustment (FPAA) addressed to M as tax matters partner (TMP) of C. Thereafter, R mailed the FPAA to notice partners, one of whom filed a timely petition for readjustment. Held, the assertion of the bar of the statute of limitations is an affirmative defense in TEFRA partnership proceedings and not a jurisdictional question. Barbados #7 v. Commissioner,92 T.C. 804 (1989), and…
1Opinion of the Court
Columbia Building, Ltd., Thomas S. Brodie, a Partner Other Than the Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent
Columbia Bldg. v. Commissioner
Docket No. 20549-88
United States Tax Court
98 T.C. 607; 1992 U.S. Tax Ct. LEXIS 45; 98 T.C. No. 40;
May 14, 1992, Filed
An order will be issued vacating the denial of the participating partners' motion for summary judgment on all issues and reinstating and granting said motion.
In 1987, M, the sole general partner of C (a partnership subject to the unified audit and litigation procedures), filed a petition in bankruptcy.…
2Cases cited7 opinions
- Robinson v. CommissionerUnited States Tax Court · 1972
- Badger Materials, Inc. v. CommissionerUnited States Tax Court · 1963
- Columbia Bldg. v. CommissionerUnited States Tax Court · 1992
- Chomp Assoc. v. CommissionerUnited States Tax Court · 1988
- Barbados 7 Ltd. v. CommmmissionerUnited States Tax Court · 1989
2 more not listed; retrieve them via the Exa API.