Rollercade, Inc. v. Commissioner
United States Tax Court
R issued a notice of final S corporation administrative adjustment (FSAA) to S Corp for its taxable year ended September 30, 1986, disallowing a deduction claimed with respect to contracted services. VF, as tax matters person, filed a timely petition for readjustment, asserting that VF would substantiate the claimed deduction.
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R issued a notice of final S corporation administrative adjustment (FSAA) to S Corp for its taxable year ended September 30, 1986, disallowing a deduction claimed with respect to contracted services. VF, as tax matters person, filed a timely petition for readjustment, asserting that VF would substantiate the claimed deduction. VF never provided R with substantiation, never responded to R's attempts to schedule conferences, failed to file a trial memorandum, and failed to appear for trial, thereby failing to comply with the Court's Rules and Standing Pre-Trial Order, and failed to comply with…
1Opinion of the Court
OPINION
BEGHE, Judge:
This matter is before us on respondent’s motions to dismiss for failure properly to prosecute and to impose sanctions on petitioner pursuant to section 6673.1
Background
Rollercade, Inc. (Rollercade), is an S corporation that operates a roller-skating rink in Detroit, Michigan. Victor E. Folks (petitioner), Rollercade’s tax matters person, has an office in River Rouge, Michigan.
On January 30, 1990, respondent sent petitioner, as Rollercade’s tax matters person, a notice of final S corporation administrative adjustment (FSAA), disallowing a deduction of $7,140 claimed by…
2Cases cited8 opinions
- Maxwell v. CommissionerUnited States Tax Court · 1986
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Dusha v. CommissionerUnited States Tax Court · 1984
- Ritchie v. CommissionerUnited States Tax Court · 1979
- Levy v. CommissionerUnited States Tax Court · 1986
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Harper v. CommissionerUnited States Tax Court · 1992
- Bagby v. CommissionerUnited States Tax Court · 1994
- Tipton v. Comm'rUnited States Tax Court · 2006
- Fifer v. CommissionerUnited States Tax Court · 1993
- BAGBY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1994
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