Legal Opinion
Medical & Business Facilities, Ltd. v. Commissioner
Court of Appeals for the Fifth Circuit
Decided July 25, 1995No. 94-40453, 94-40527PublishedCited by 2 opinions
1Opinion of the Court
PATRICK E. HIGGINBOTHAM, Circuit Judge:
A general partner of Medical & Business Facilities, Ltd. signed consent forms for tax years 1983 through 1986, agreeing to extend the period of limitations during which the Internal Revenue Service could assess a deficiency. MBFL is now arguing that the general partner was not authorized to execute the consents and the IRS’s assessment is time barred. We agree and reverse the Tax Court’s finding in favor of the Commissioner.
I
Medical & Business Facilities, Ltd. was a partnership engaged in the business of buying medical assets and leasing those assets to…
2Cases cited8 opinions
- Conrad Keado v. United States of America, Conrad L. Keado and Linda W. Keado v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Clemon J. And Ivy C. Herrington v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Lewis v. CommissionerCourt of Appeals for the First Circuit · 1994
- Cambridge Research & Dev. Group v. CommissionerUnited States Tax Court · 1991
- Shearn Moody, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1986
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3Cited by2 opinions
- AD Global Fund, LLC ex rel. North Hills Holding, Inc. v. United StatesUnited States Court of Federal Claims · 2005
- Peking Inv. Fund, LLC v. Comm'rUnited States Tax Court · 2013