Asa Investerings P'Ship v. Comm'r
United States Tax Court
P filed a motion to redetermine interest under sec. 7481(c), I.R.C. R moves to dismiss for lack of jurisdiction on the basis that a sec. 6215, I.R.C., assessment has not been made.
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P filed a motion to redetermine interest under sec. 7481(c), I.R.C. R moves to dismiss for lack of jurisdiction on the basis that a sec. 6215, I.R.C., assessment has not been made. Held : Sec. 7481(c), I.R.C., requires that "an assessment has been made by the Secretary under section 6215". An assessment under sec. 6215, I.R.C., can only occur where a notice of deficiency has been issued, a sec. 6213(a), I.R.C., petition has been filed, and the Tax Court has redetermined or sustained a deficiency by a decision that has become final. The instant case involves a unified partnership proceeding…
1Opinion of the Court
ASA INVESTERINGS PARTNERSHIP, ALLIEDSIGNAL, INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Asa Investerings P'Ship v. Comm'r
No. 27320-96.
United States Tax Court
118 T.C. 423; 2002 U.S. Tax Ct. LEXIS 26; 118 T.C. No. 26;
May 22, 2002, Filed
Petitioner's motion to redetermine interest denied for lacked of jurisdiction.
P filed a motion to redetermine interest under sec.
7481(c), I.R.C. R moves to dismiss for lack of jurisdiction on
the basis that a sec. 6215, I.R.C., assessment has not been
made.
Held : Sec. 7481(c), I.R.C., requires that "an
assessment has been…
2Cases cited15 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Monge v. CommissionerUnited States Tax Court · 1989
- William H. Kenner and Eleanor v. Kenner v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1968
- White v. CommissionerUnited States Tax Court · 1990
- Asa Investerings Partnership,appellants v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 2000
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