Legal Opinion

Blanco Inv. & Land, Ltd. v. Commissioner

United States Tax Court

Decided December 10, 1987No. Docket No. 14022-87PublishedCited by 19 opinions

P is the tax matters person of B, an S corporation which, during its 1983 taxable year, had only one shareholder. R examined B's Federal income tax return pursuant to the S corporation audit and litigation procedures, sec. 6241 et seq., and issued a Notice of Final S Corporation Administrative Adjustment (FSAA). The partnership audit and litigation procedures were, in general, grafted onto the S corporation audit and litigation procedures except as modified or made…

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P is the tax matters person of B, an S corporation which, during its 1983 taxable year, had only one shareholder. R examined B's Federal income tax return pursuant to the S corporation audit and litigation procedures, sec. 6241 et seq., and issued a Notice of Final S Corporation Administrative Adjustment (FSAA). The partnership audit and litigation procedures were, in general, grafted onto the S corporation audit and litigation procedures except as modified or made inapplicable by regulations. In 1983, there were no regulations under the S corporation audit and litigation procedures. Held:…

1Opinion of the Court

OPINION

WILLIAMS, Judge:

This case is before us on petitioner’s motions to dismiss for lack of jurisdiction and for litigation costs. The Commissioner determined adjustments to Blanco Investments & Land, Ltd.’s (Blanco) S corporation return for its 1983 taxable year as set forth in a Notice of Final S Corporation Administrative Adjustment.

Petitioner contends that Blanco was exempt from the S corporation audit and litigation procedures of subchapter D of chapter 63 of subtitle F, sec. 6241 et seq.,1 in 1983 because it had only one shareholder. Respondent argues that there was no small S…

2Cited by19 opinions

  1. Fehlhaber v. CommissionerUnited States Tax Court · 1990
  2. Dial USA, Inc. v. CommissionerUnited States Tax Court · 1990
  3. Robert Fehlhaber v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1992
  4. 111 West 16 Street Owners, Inc. v. CommissionerUnited States Tax Court · 1988
  5. Arenjay Corporation, A. James Sedwick, Jr., Tax Matters Person v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991

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