Blanco Inv. & Land, Ltd. v. Commissioner
United States Tax Court
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…
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- 111 West 16 Street Owners, Inc. v. CommissionerUnited States Tax Court · 1988
- 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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