Energy Resources, Ltd. v. Commissioner
United States Tax Court
A notice of final partnership administrative adjustment was issued to the tax matters partner of ER, a limited partnership. No petition was filed by the tax matters partner. C, who held a 0.495-percent interest in the partnership, received a notice of final partnership administrative adjustment. C filed a petition as a partner other than the tax matters partner of ER. The partnership had in excess of 100 partners.
Read the full summary
A notice of final partnership administrative adjustment was issued to the tax matters partner of ER, a limited partnership. No petition was filed by the tax matters partner. C, who held a 0.495-percent interest in the partnership, received a notice of final partnership administrative adjustment. C filed a petition as a partner other than the tax matters partner of ER. The partnership had in excess of 100 partners. Held, C is not entitled to the notice specified in sec. 6223(a), I.R.C. 1954, and is not a notice partner under sec. 6231(a)(8). Held, further, C is not entitled to file a petition…
1Opinion of the Court
OPINION
NlMS, Judge:
This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.1 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction. The issue before the Court is whether John C. Coggin III (hereinafter Coggin) is a party entitled to file a petition under section 6226(b).
FINDINGS OF FACT
A notice of final partnership administrative adjustment,…
2Cases cited1 opinion
- Liberty Finance Service, Inc. v. CommissionerUnited States Tax Court · 1960
3Cited by15 opinions
- Abel Kaplan and Mary Lou Kaplan v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Blonien v. Comm'rUnited States Tax Court · 2002
- 1983 Western Reserve Oil & Gas Co. v. CommissionerUnited States Tax Court · 1990
- Wood v. CommissionerUnited States Tax Court · 1990
- Prestop Holdings, LLC v. United StatesUnited States Court of Federal Claims · 2010
10 more not listed; retrieve them via the Exa API.