Computer Programs Lambda, Ltd. v. Commissioner
United States Tax Court
In our previous opinion, reported at 89 T.C. 198 (filed July 27, 1987), we held that P's general partners were ineligible to serve as tax matters partner because they were debtors in a bankruptcy proceeding. Sec. 301.6231(c)-7T(a), Temp. Proced. & Admin. Regs., 52 Fed.
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In our previous opinion, reported at 89 T.C. 198 (filed July 27, 1987), we held that P's general partners were ineligible to serve as tax matters partner because they were debtors in a bankruptcy proceeding. Sec. 301.6231(c)-7T(a), Temp. Proced. & Admin. Regs., 52 Fed. Reg. 6793 (Mar. 5, 1987). Prior to this litigation, R did not select a tax matters partner for P pursuant to sec. 6231(a)(7). Held, because a tax matters partner is essential to the operation of the statutory procedures of secs. 6221 et seq., and to the fair, efficient, and consistent disposition of partnership proceedings…
1Opinion of the Court
OPINION
WILLIAMS, Judge:
The Commissioner determined adjustments to Computer Programs Lambda, Ltd.’s (CPL) partnership return for 1982 as set forth in his notice of final partnership administrative adjustment issued on March 11, 1986. We must decide whether this Court may appoint a limited partner of CPL to act as tax matters partner on behalf of the partnership solely for purposes of this litigation.
In our previously reported opinion at 89 T.C. 198 (filed July 27, 1987), we held that CPL’s tax matters partner, Pyke International, Inc. (Pll), ceased to be CPL’s tax matters partner upon its…
2Cases cited8 opinions
- Link v. Wabash RailroadSupreme Court of the United States · 1962
- Roadway Express, Inc. v. PiperSupreme Court of the United States · 1980
- United States v. BaggotSupreme Court of the United States · 1983
- Computer Programs Lambda, Ltd. v. CommissionerUnited States Tax Court · 1987
- Amos v. Board of School Directors of City of MilwaukeeDistrict Court, E.D. Wisconsin · 1976
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