Legal Opinion
Bufferd v. Commissioner
Supreme Court of the United States
Decided January 25, 1993No. 91-7804PublishedCited by 100 opinions
1Opinion of the CourtJustice White
On his 1979 income tax return, petitioner, a shareholder in a Subchapter S corporation, claimed as “pass-through” items portions of a deduction and a tax credit reported on the corporation’s return. The question presented is whether the 3-year period in which the Internal Revenue Service is permitted to assess petitioner’s tax liability runs from the filing date of the individual return or the corporate return. We conclude with the Tax Court and the Court of Appeals for the Second Circuit that the relevant date is that on which petitioner’s return was filed.
I
Subchapter S of the Internal…
2Cases cited17 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Seatrain Shipbuilding Corp. v. Shell Oil Co.Supreme Court of the United States · 1980
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
12 more not listed; retrieve them via the Exa API.
3Cited by100 opinions
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Gitlitz v. CommissionerSupreme Court of the United States · 2001
- Walter L. Gross, Jr. And Barbara H. Gross (99-2239) Calvin C. Linnemann and Patricia G. Linnemann (99-2257) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2001
- Neer v. State Ex Rel. Oklahoma Tax CommissionSupreme Court of Oklahoma · 1999
95 more not listed; retrieve them via the Exa API.