Eastern States Casualty Agency, Inc. v. Commissioner
United States Tax Court
R issued a notice of final S corporation administrative adjustment (FSAA) to E for its taxable year ending Dec. 31, 1984. E, an S corporation, had four shareholders during 1984. P, as tax matters person, filed a timely petition for readjustment and a motion to dismiss for lack of jurisdiction.
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R issued a notice of final S corporation administrative adjustment (FSAA) to E for its taxable year ending Dec. 31, 1984. E, an S corporation, had four shareholders during 1984. P, as tax matters person, filed a timely petition for readjustment and a motion to dismiss for lack of jurisdiction. P contends that the FSAA is invalid because S corporations with 10 or fewer shareholders are excepted from the unified audit and litigation procedures pursuant to I.R.C. sec. 6244 and 6231(a)(1)(B). Held, prior to the effective date of sec. 301.6241-1T(c), Temporary Proced. & Admin. Regs., no S…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This case is before the Court on petitioner’s motion to dismiss for lack of jurisdiction. The issue for decision is whether an S corporation with four shareholders is excepted from the unified audit and litigation procedures contained in section 6241 et seq. (Unless otherwise indicated, section references are to the Internal Revenue Code as in effect for the year in issue.)
Background
In a notice of final S corporation administrative adjustment (FSAA) issued on December 20, 1989, respondent determined adjustments to the S corporation return filed by Eastern States…
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