(Download) "Callaway v. Commissioner of Internal Revenue" by Second Circuit U.S. Court Of Appeals * Book PDF Kindle ePub Free
eBook details
- Title: Callaway v. Commissioner of Internal Revenue
- Author : Second Circuit U.S. Court Of Appeals
- Release Date : January 15, 2000
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 81 KB
Description
Appeal from the Tax Court. Taxpayers deceased spouse held partnership interest. Following TEFRA audit of partnership return, IRS assessed taxes attributable to spouses distributive share of disallowed losses by computational adjustment. IRS then issued affected items notices of deficiency to taxpayer and decedents estate determining various additions to tax. Taxpayer and the estate filed timely petition for redetermination. The Tax Court (Peter J. Panuthos, Chief Special Trial Judge) held: (1) as to decedents estate, filing of request for prompt assessment meant deficiency notices were invalid and therefore court lacked jurisdiction; but (2) as to taxpayer, the deficiency notices were valid and the statute of limitations did not bar the computational adjustments or the subsequent determinations of additions to tax. See Callaway v. Commissioner, 75 T.C.M. (CCH) 1956 (1998). Taxpayer and the IRS settled certain issues by agreement, pursuant to which a stipulated decision entered, preserving petitioners right to appeal the statute of limitations ruling. This appeal followed.
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