Huff v. Commissioner
United States Tax Court
Claiming to be a bona fide resident of the U.S.Virgin Islands (Virgin Islands) and claiming he was qualified for the gross income tax exclusion provided by I.R.C. sec. 932(c)(4), P, a U.S. citizen, filed territorial income tax returns with, and paid income tax to, the Virgin Islands Bureau of Internal Revenue (BIR) for 2002, 2003, and 2004 (years involved). P did not file Federal income tax returns with, or pay Federal income tax to, the Internal Revenue Service (IRS) for…
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Claiming to be a bona fide resident of the U.S.Virgin Islands (Virgin Islands) and claiming he was qualified for the gross income tax exclusion provided by I.R.C. sec. 932(c)(4), P, a U.S. citizen, filed territorial income tax returns with, and paid income tax to, the Virgin Islands Bureau of Internal Revenue (BIR) for 2002, 2003, and 2004 (years involved). P did not file Federal income tax returns with, or pay Federal income tax to, the Internal Revenue Service (IRS) for those years. P asserts he was a member of NASCO Corporate Finance Consultants, LLC (NASCO), a Virgin Islands limited…
1Opinion of the Court
OPINION
Jacobs, Judge:
This matter is before the Court on petitioner’s motion to dismiss for lack of jurisdiction (petitioner’s motion), the resolution of which turns on whether respondent should have issued a notice of final partnership administrative adjustment (FPAA) to the tax matters partner (tmp) of NASCO Corporate Finance Consultants, LLC (NASCO), pursuant to the procedural rules of the Tax Equity and Fiscal Responsibility Act of 1982 (tefra), Pub. L. No. 97-248, sec. 402(a), 96 Stat. at 648, rather than issue, as respondent did, a notice of deficiency to petitioner.
Background 1
I.…
2Cases cited18 opinions
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Beard v. Comm'rUnited States Tax Court · 1984
- Robert D. Beard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Cook v. TaitSupreme Court of the United States · 1924
13 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
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- Judith Coffey v. CIRCourt of Appeals for the Eighth Circuit · 2021
- Arthur I. Appleton, Jr. , and The Government of the United States Virgin Islands, Intervenor v. CommissionerUnited States Tax Court · 2013
- Appleton v. Comm'rUnited States Tax Court · 2013
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