Case: Notice of Deficiency Timely Issued (T.C. Memo) (IRC §6229)

The U.S. Tax Court granted partial summary judgment to the IRS holding that the IRS’s issuance of affected items notices of deficiency for tax years 2000, 2001, and 2003 was timely. The taxpayer, an individual, had participated in a tax shelter transaction through a partnership entity in 2000, claiming losses that were later disallowed. The IRS issued a Final Partnership Administrative Adjustment (FPAA) to the partnership in 2005, which was challenged in district court. The district court upheld the timeliness of the FPAA, a decision affirmed by the appeals court and denied certiorari by the Supreme Court in 2018. The ...