Bhupindar S. and Rajinder K. Dhillon - Page 1

                                 T.C. Memo. 1999-214                                  

                               UNITED STATES TAX COURT                                

                BHUPINDAR S. AND RAJINDER K. DHILLON, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16971-98.                     Filed July 1, 1999.           

                    R filed a motion to dismiss for lack of jurisdiction on           
               the ground that Ps did not file their petition for                     
               redetermination within the time prescribed by sec. 6213(a),            
               I.R.C.  Ps, 50-percent partners in E, contend that their               
               petition was timely filed.  Ps argue that the extended time            
               for filing a petition under sec. 6226(b)(1), I.R.C., of the            
               partnership audit and litigation procedures, secs. 6221-               
               6232, I.R.C., enacted as part of the Tax Equity and Fiscal             
               Responsibility Act of 1982, Pub. L. 97-248, sec. 402(a), 96            
               Stat. 648 (TEFRA partnership procedures), governs the period           
               for filing the petition because R's adjustments in the                 
               notice of deficiency relate to adjustments of flow-through             
               partnership items of E.                                                
                    Held:  E is a "small partnership" under sec.                      
               6231(a)(1)(B)(i), I.R.C., and is therefore not a partnership           
               covered by the TEFRA partnership procedures.  Thus, the                
               extended period for filing a petition for redetermination              
               under sec. 6226(b)(1), I.R.C., does not apply in this case.            

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