Partner Who Signed Individual Settlement Agreement Waived Right to Contest Validity of Partnership's Waiver of Statute of Limitations
Article Abstract:
The Court of Federal Claims held that when the taxpayer enters into a settlement with the Internal Revenue Service with respect to his share of a partnership item, his share is converted into a non-partnership item, and applied the statute of limitations accordingly.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1997
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Partnerships - IRS finds method of allocation of excess nonrecourse liabilities inappropriate
Article Abstract:
The allocation of 100% of third-tier excess non-recourse liabilities to a partner under Reg. 1.752-3(a) (3) where the basis for the allocation was a gross income allocation, was found to be inappropriate by the IRS. The ruling was given in the TAM 200436011 case.
Publication Name: Business Entities
Subject: Business
ISSN: 1524-3583
Year: 2005
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Statute of Limitations to Assess Additional Taxes Against a Tax Shelter Partnership Extended Because Signing Partner Had Intent to Evade Tax
Article Abstract:
The Court of Federal Claims ruled that the statute of limitations applied in cases where filing of returns by a limited partner was with intent to evade taxes.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1997
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