Asa Investerings Partnership, Alliedsignal, Inc., Tax Matters Partner - Page 1

                                   118 T.C. No. 26                                    

                               UNITED STATES TAX COURT                                

                               PARTNER, Petitioner v.                                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 27320-96.               Filed May 22, 2002.                 

                    P filed a motion to redetermine interest under                    
               sec. 7481(c), I.R.C.  R moves to dismiss for lack of                   
               jurisdiction on the basis that a sec. 6215, I.R.C.,                    
               assessment has not been made.                                          
                    Held:  Sec. 7481(c), I.R.C., requires that “an                    
               assessment has been made by the Secretary under section                
               6215”.  An assessment under sec. 6215, I.R.C., can only                
               occur where a notice of deficiency has been issued, a                  
               sec. 6213(a), I.R.C., petition has been filed, and the                 
               Tax Court has redetermined or sustained a deficiency by                
               a decision that has become final.  The instant case                    
               involves a unified partnership proceeding for the                      
               readjustment of partnership items.  See secs. 6221-                    
               6234, I.R.C.  Deficiencies are not redetermined by Tax                 
               Court decisions in unified partnership proceedings, and                
               no deficiencies have been redetermined by the Tax Court                
               in this case.  See ASA Investerings Pship. v.                          

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