Estate of Fry v. Commissioner
United States Tax Court
Held, petitioners' 1976 income tax return failed to make a disclosure sufficient to invoke the exception to the 6-year statute of limitations set forth in sec. 6501(e)(1)(A)(ii), I.R.C. 1954.
1Opinion of the Court
OPINION
WHITAKER, Judge-.
Respondent determined a deficiency in the Federal income tax liability of Mr. William F.L. Fry and his wife Mrs. Grace H. Fry for their calendar year 1976 in the amount of $840,298.18.1 This case is before the Court on petitioners’ motion for partial summary judgment which raises the issue as to the timeliness of issuance of the statutory notice. The statutory notice is dated June 20, 1983, which is more than 3 years after the filing of the 1976 Federal income tax return. Respondent relies on the provisions of section 6501(e)(1)(A)2 — the 6-year period of limitations.3…
2Cases cited6 opinions
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Reis v. CommissionerUnited States Tax Court · 1942
- Roschuni v. CommissionerUnited States Tax Court · 1965
- University Country Club, Inc. v. CommissionerUnited States Tax Court · 1975
- Benderoff v. United StatesCourt of Appeals for the Eighth Circuit · 1968
1 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Highwood Partners v. Comm'rUnited States Tax Court · 2009
- Harlan v. Comm'rUnited States Tax Court · 2001
- Salman Ranch Ltd. v. United StatesUnited States Court of Federal Claims · 2007
- CNT Investors, LLC v. Comm'rUnited States Tax Court · 2015
17 more not listed; retrieve them via the Exa API.