Barbados 7 Ltd. v. Commmmissioner
United States Tax Court
Bajan, the sole general partner of three limited partnerships, Barbados Nos. 7, 8 and 9, was designated tax matters partner (TMP) for each of the limited partnerships on the 1983 partnership returns. On Aug. 1, 1985, Bajan filed a petition in bankruptcy under Chapter 11 of the Bankruptcy Code.
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Bajan, the sole general partner of three limited partnerships, Barbados Nos. 7, 8 and 9, was designated tax matters partner (TMP) for each of the limited partnerships on the 1983 partnership returns. On Aug. 1, 1985, Bajan filed a petition in bankruptcy under Chapter 11 of the Bankruptcy Code. On Jan. 5, 1987, Bajan executed extensions of the statute of limitations on behalf of the limited partnerships extending the time to issue notices of Final Partnership Administrative Adjustment (FPAA's). On June 22, 1987, duplicate original FPAA's were issued to two of the limited partnerships. On July…
1Opinion of the Court
OPINION
Scott, Judge:
This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.2 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Special Trial Judge:
These cases came before the Court on petitioner’s motions for summary judgment and petitioner’s motions to dismiss for lack of jurisdiction. The issues for decision are (1) whether these cases must be dismissed for lack of jurisdiction for respondent’s alleged failure to mail the notices of final…
2Cases cited14 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Helvering v. SalvageSupreme Court of the United States · 1936
- Computer Programs Lambda, Ltd. v. CommissionerUnited States Tax Court · 1987
9 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Columbia Bldg. v. CommissionerUnited States Tax Court · 1992
- Transpac Drilling Venture 1982-12, Guy J. Cutili v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1998
- 1983 Western Reserve Oil & Gas Co. v. CommissionerUnited States Tax Court · 1990
- Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1991
- Fazi v. CommissionerUnited States Tax Court · 1995
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