Greenwald v. Comm'r
United States Tax Court
Ps owned interests in bona fide partnerships that were subject to the tax audit and litigation procedures of I.R.C. secs. 6221-6234. The partnerships liquidated, and the partnership items for the year of liquidation were determined in partnership-level proceedings. Following those proceedings, R issued notices of deficiency determining the partners' gain on liquidation of the partnerships.
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Ps owned interests in bona fide partnerships that were subject to the tax audit and litigation procedures of I.R.C. secs. 6221-6234. The partnerships liquidated, and the partnership items for the year of liquidation were determined in partnership-level proceedings. Following those proceedings, R issued notices of deficiency determining the partners' gain on liquidation of the partnerships. Ps filed petitions in response to those notices of deficiency and later moved to dismiss for lack of jurisdiction, arguing that outside basis is a partnership item that should have been determined at the…
1Opinion of the Court
ISRAEL GREENWALD AND RUTH GREENWALD, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Greenwald v. Comm'r
Docket Nos. 29126-11, 29244-11, 3203-12, 3212-12, 3213-12, 3215-12, 3216-12, 3217-12, 3218-12.
United States Tax Court
142 T.C. 308; 2014 U.S. Tax Ct. LEXIS 19; 142 T.C. No. 18;
May 21, 2014, Filed
An appropriate order will be issued.
Ps owned interests in bona fide partnerships that were subject to the tax audit and litigation procedures of I.R.C. secs. 6221-6234. The partnerships liquidated, and the partnership items for the year of liquidation were determined in…
2Cases cited8 opinions
- United States v. WoodsSupreme Court of the United States · 2013
- Desmet v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2009
- Domulewicz v. Comm'rUnited States Tax Court · 2007
- New Millennium Trading, L.L.C. v. Comm'rUnited States Tax Court · 2008
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
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