Estate of Quick v. Commissioner
United States Tax Court
P was a limited partner in a partnership subject to the unified audit and litigation provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648. R issued notices of computational adjustment to Ps, pursuant to which deficiencies for taxable years 1987 through 1990 were assessed.
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P was a limited partner in a partnership subject to the unified audit and litigation provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648. R issued notices of computational adjustment to Ps, pursuant to which deficiencies for taxable years 1987 through 1990 were assessed. In the computational adjustment notices for 1989 and 1990, R recharacterized Ps' distributive share of partnership losses for those years as passive for purposes of sec. 469, I.R.C. R thereafter issued affected items notices of deficiency to Ps for 1987…
1Opinion of the Court
ESTATE OF ROBERT W. QUICK, DECEASED, ESTHER P. QUICK, PERSONAL REPRESENTATIVE, AND ESTHER P. QUICK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Quick v. Commissioner
Tax Ct. Dkt. No. 8588-97
United States Tax Court
110 T.C. 172; 1998 U.S. Tax Ct. LEXIS 18; 110 T.C. No. 17;
March 16, 1998, Filed
An appropriate order granting petitioners' motion for leave to file amendment to petition and respondent's motion for leave to file amendment to answer, and denying petitioners' motion for summary judgment, will be issued.
P was a limited partner in a partnership subject to the…
2Cases cited19 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
- Maxwell v. CommissionerUnited States Tax Court · 1986
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