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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