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.

Taxpayer compliance

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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.

Legal issues & crime, Legal/Government Regulation, Liabilities (Accounting), Company legal issue, Reports, United States. Internal Revenue Service

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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.

Tax evasion, Tax shelters, Transpac Drilling Venture 1832-2

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