Legal Opinion

Harlan v. Comm'r

United States Tax Court

Decided January 17, 2001No. 21214-92; No. 24609-92Published

Ps are partners in partnerships (the 1st-tier partnerships); some of the 1st-tier partnerships are partners in other partnerships (the 2d-tier partnerships). R maintains that the 6-year period of limitations under sec. 6501(e)(1)(A), I.R.C. 1986, applies to notices of deficiency sent in 1992 with respect to Ps' 1985 tax year.

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Ps are partners in partnerships (the 1st-tier partnerships); some of the 1st-tier partnerships are partners in other partnerships (the 2d-tier partnerships). R maintains that the 6-year period of limitations under sec. 6501(e)(1)(A), I.R.C. 1986, applies to notices of deficiency sent in 1992 with respect to Ps' 1985 tax year. In determining the applicability of sec. 6501(e)(1)(A), I.R.C. 1986, R includes in Ps' "gross income stated in the return" Ps' distributive shares of the gross incomes of the 1st-tier partnerships, but does not take account of the 1st-tier partnerships' distributive…

1Opinion of the Court

RIDGE L. HARLAN AND MARJORY C. HARLAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent THEODORE S. OCKELS AND ROSEMARIE G. OCKELS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Harlan v. Comm'r

No. 21214-92; No. 24609-92

United States Tax Court

116 T.C. 31; 2001 U.S. Tax Ct. LEXIS 4; 116 T.C. No. 4; 2001-1 U.S. Tax Cas. (CCH) P54,209;

January 17, 2001, Filed

Our holding in this opinion will be incorporated into the decision to be entered in these cases when all the other issues are resolved.

Ps are partners in partnerships (the 1st-tier

partnerships); some of the 1st-tier…

2Cases cited37 opinions

  1. Commissioner v. LundySupreme Court of the United States · 1996
  2. Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
  3. Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
  4. Stratton v. CommissionerUnited States Tax Court · 1970
  5. Reis v. CommissionerUnited States Tax Court · 1942

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