- 2 - I.R.C., provides the general rule that R has 3 years after the “return” was filed to assess. R contends that the “return” referenced in sec. 6501(a), I.R.C., is the return of the taxpayer for whom the adjustment is being made. Conversely, P contends that the “return” is that of the entity from which the adjustment derives. Held: In the factual context of this case, the return referenced in sec. 6501(a), I.R.C., is the return of the taxpayer for whom the adjustment is determined and not the return of the entity from or concerning whom the taxpayer has realized an item of income. Roger M. Schrimp, James F. Lewis, and Steven G. Pallios, for petitioners. Michael F. Steiner, Julie A. Howell, and Dale A. Zusi, for respondent. GERBER, Judge: In separate notices of deficiency, respondent determined deficiencies in petitioners’ Federal income tax and accuracy-related penalties under section 66622 for the 1992, 1993, and 1994 taxable years as follows: 2 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable years under consideration, and Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 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