129 T.C. No. 13
UNITED STATES TAX COURT
PETER D. ADKISON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2532-06. Filed October 16, 2007.
R sent to P a notice of deficiency for 1999. P
filed a petition seeking to invoke the Court’s
jurisdiction to redetermine the deficiency and to
decide P’s claim for relief under sec. 6015(c), I.R.C.
R moved to dismiss for lack of jurisdiction on the
grounds (1) the notice of deficiency is invalid because
the underlying adjustments constitute “partnership
items” that are the subject of an ongoing partnership-
level proceeding in Federal District Court, and (2) P’s
claim for relief under sec. 6015(c), I.R.C.,
constitutes an “affected item” that can be reviewed
only after the partnership-level proceeding is
completed.
The parties agree that the notice of deficiency is
invalid because the underlying adjustments constitute
“partnership items” that are the subject of an ongoing
partnership-level proceeding in Federal District Court.
P opposes dismissal of his claim under sec. 6015(c),
I.R.C.
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Last modified: November 10, 2007