T.C. Memo. 1997-548 UNITED STATES TAX COURT LARRY BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13623-96. Filed December 11, 1997. R moved for partial summary judgment on an issue informally raised by P during an IRS Appeals Office conference as to whether the period of limitations for assessment had expired as a result of R's alleged failure to honor an election by P's partnership for treatment under the unified audit provisions of secs. 6221 through 6233, I.R.C. R also moved to impose sanctions under Rule 104(c), Tax Court Rules of Practice and Procedure, including dismissal, for P's ongoing noncompliance with a discovery order of the Court. P filed oppositions to both of R's motions. 1. Held: R's motion for partial summary judgment granted. Rule 121(b), Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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