Bradley v. Commissioner
United States Tax Court
Respondent moved to dismiss for lack of jurisdiction as to partnership items which had previously been disposed of in an administrative proceeding.
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Respondent moved to dismiss for lack of jurisdiction as to partnership items which had previously been disposed of in an administrative proceeding. Petitioner objects on the grounds (1) the reference to the deficiency in respect of the partnership items contained in the statutory notice is sufficient to confer jurisdiction of those items, (2) the notice of final partnership administrative adjustment (FPAA) was untimely because it was issued after the period of limitations had expired, and (3) the statutory notice was invalid because petitioner did not receive a notice of computational…
1Opinion of the Court
GEORGE WAYNE BRADLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bradley v. Commissioner
Docket No. 25729-91
United States Tax Court
100 T.C. 367; 1993 U.S. Tax Ct. LEXIS 23; 100 T.C. No. 23;
April 19, 1993, Filed
Respondent moved to dismiss for lack of jurisdiction as to partnership items which had previously been disposed of in an administrative proceeding. Petitioner objects on the grounds (1) the reference to the deficiency in respect of the partnership items contained in the statutory notice is sufficient to confer jurisdiction of those items, (2) the notice of final…
2Cases cited16 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Adler v. CommissionerUnited States Tax Court · 1985
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- Charles Crowther and Ivy L. Crowther v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
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