Energy Resources, Ltd. v. Commissioner
United States Tax Court
A notice of final partnership administrative adjustment was issued to the tax matters partner of ER, a limited partnership. No petition was filed by the tax matters partner. C, who held a 0.495-percent interest in the partnership, received a notice of final partnership administrative adjustment. C filed a petition as a partner other than the tax matters partner of ER. The partnership had in excess of 100 partners.
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A notice of final partnership administrative adjustment was issued to the tax matters partner of ER, a limited partnership. No petition was filed by the tax matters partner. C, who held a 0.495-percent interest in the partnership, received a notice of final partnership administrative adjustment. C filed a petition as a partner other than the tax matters partner of ER. The partnership had in excess of 100 partners. Held, C is not entitled to the notice specified in sec. 6223(a), I.R.C. 1954, and is not a notice partner under sec. 6231(a)(8). Held, further, C is not entitled to file a petition…
1Opinion of the Court
Energy Resources, Ltd., John C. Coggin III, a Partner Other Than the Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent
Energy Resources, Ltd. v. Commissioner
Docket No. 26143-87
United States Tax Court
91 T.C. 913; 1988 U.S. Tax Ct. LEXIS 138; 91 T.C. No. 56;
November 8, 1988; As amended December 6, 1988 November 8, 1988, Filed
An order of dismissal will be entered.
A notice of final partnership administrative adjustment was issued to the tax matters partner of ER, a limited partnership. No petition was filed by the tax matters partner. C, who held a 0.495-percent…
2Cases cited2 opinions
- Energy Resources, Ltd. v. CommissionerUnited States Tax Court · 1988
- Liberty Finance Service, Inc. v. CommissionerUnited States Tax Court · 1960