Peter D. Adkison - Page 1















                                   129 T.C. No. 13                                    


                               UNITED STATES TAX COURT                                


                           PETER D. ADKISON, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2532-06.               Filed October 16, 2007.              


                    R sent to P a notice of deficiency for 1999.  P                   
               filed a petition seeking to invoke the Court’s                         
               jurisdiction to redetermine the deficiency and to                      
               decide P’s claim for relief under sec. 6015(c), I.R.C.                 
               R moved to dismiss for lack of jurisdiction on the                     
               grounds (1) the notice of deficiency is invalid because                
               the underlying adjustments constitute “partnership                     
               items” that are the subject of an ongoing partnership-                 
               level proceeding in Federal District Court, and (2) P’s                
               claim for relief under sec. 6015(c), I.R.C.,                           
               constitutes an “affected item” that can be reviewed                    
               only after the partnership-level proceeding is                         
               completed.                                                             
                    The parties agree that the notice of deficiency is                
               invalid because the underlying adjustments constitute                  
               “partnership items” that are the subject of an ongoing                 
               partnership-level proceeding in Federal District Court.                
               P opposes dismissal of his claim under sec. 6015(c),                   
               I.R.C.                                                                 






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Last modified: November 10, 2007