T.C. Memo. 2007-88
UNITED STATES TAX COURT
THOMAS J. NEHRLICH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20720-04L. Filed April 12, 2007.
Patrick J. Quinn, for petitioner.
Catherine G. Chang, for respondent.
MEMORANDUM OPINION
HOLMES, Judge: After a partnership named JTA Research was
audited, one of its partners filed a petition in this Court
challenging the disallowance of a large charitable deduction.
But he filed the petition too late and we dismissed it for lack
of jurisdiction. The Commissioner then assessed each of JTA's
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Last modified: November 10, 2007