Legal Opinion

Stahl v. Commissioner

United States Tax Court

Decided June 10, 1991No. Docket No. 29441-85PublishedCited by 47 opinions

Held: With respect to 1979 and 1980, the filing of partnership information returns does not affect the statute of limitations relating to respondent's authority to determine deficiencies against individual partners of a partnership. Kelley v. Commissioner, 877 F.2d 756 (9th Cir. 1989), revg. and remanding T.C. Memo. 1986-405, relating to subchapter S returns, is inapplicable.

1Opinion of the Court

SUPPLEMENTAL OPINION

SWIFT, Judge:

Petitioners move to vacate and revise our opinion herein filed on June 26, 1990. See Stahl v. Commissioner, T.C. Memo. 1990-320.

Petitioners’ motion is based on the contention that respondent’s notices of deficiency mailed to petitioners on May 2, 1985, were untimely because they reflect adjustments to the 1979 and 1980 income of a partnership and because respondent’s notices were mailed beyond 3 years from the time the partnership filed its information returns with respect to 1979 and 1980. Petitioners cite a decision of the U.S. Court of Appeals for the Ninth…

2Cases cited8 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. Durovic v. CommissionerUnited States Tax Court · 1970
  4. Marko Durovic v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
  5. Siben v. CommissionerCourt of Appeals for the Second Circuit · 1991

3 more not listed; retrieve them via the Exa API.

3Cited by47 opinions

  1. Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
  2. Lardas v. CommissionerUnited States Tax Court · 1992
  3. Asciutto v. CommissionerUnited States Tax Court · 1992
  4. AndersonUnited States Tax Court · 1992
  5. Bartol v. CommissionerUnited States Tax Court · 1992

42 more not listed; retrieve them via the Exa API.

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