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
Last modified: May 25, 2011