Notes of Decisions
Cemco Investors, LLC v. United States, 515 F.3d 749 (7th Cir. 2008).
“26 U.S.C. § 6222 (a). That’s why the Commissioner issued the Notice of Final Partnership Administrative Adjustment to Cemco and why it rather than Daugerdas or his client is the plaintiff.”
Bassing v. United States, 563 F.3d 1280 (Fed. Cir. 2009).
· cites it 2× “Bassing’s negative capital account balance of $882,871 was a partnership item because it represented an amount determined by the partnership under its capital account maintenance rules, which constituted an accounting practice adopted by the partnership and applicable to all the…”
Randall S. Goulding v. United States, 957 F.2d 1420 (7th Cir. 1992).
“See 26 U.S.C. § 6222 . Because appellant’s analysis of the partnership’s financial operations was in essence an analysis of income directly taxable to the partners and losses directly deductible by them, the regulation making him the preparer of their returns reflects the real…”
Russian Recovery Fund Ltd. v. United States, 101 Fed. Cl. 498 (Fed. Cl. 2011).
“Defendant asserts that FFIP was required under 26 U.S.C. § 6222 to notify the IRS that it was not reporting the losses in the same year as RRF, the partnership that assigned FFIP the losses.”
Snyder v. United States, 630 F. Supp. 182 (D. Md. 1986).
“However, 26 U.S.C. § 6222 provided that beginning on January 1, 1983 interest was to be compounded daily at the rate established under § 6621.”
United States v. Bailey, 789 F. Supp. 788 (N.D. Tex. 1992).
“See 26 U.S.C. § 6222 (1986 & Supp.1989). 7 . Although an employee is not required to treat as income reimbursement of business expenses he receives, monies received as reimbursement are taxable if the employee is not required to substantiate the expenses intended to be covered…”
Schumacher Trading Partners II v. United States, 72 Fed. Cl. 95 (Fed. Cl. 2006).
“; see also 26 U.S.C. § 6222 (a) (“A partner shall, on the partner’s return, treat a partnership item in a manner which is consistent with the treatment of such partnership item on the partnership return.”
Wallis v. Comm'r of the Internal Revenue Serv., 391 F. App'x 826 (11th Cir. 2010).
“” 26 U.S.C. § 6222 (b)(1). Given that Donald Wallis has 35 years of experience as a tax lawyer, the Tax Court reasonably could conclude that Wallis should have been aware there were inconsistencies between (1)his not reporting the Schedule C payments at all to the IRS and (2)…”
River City Ranches v. Comm'r, 401 F.3d 1136 (9th Cir. 2005).
“26 U.S.C. § 6222 (subtitle F provision for administering subtitle A requirements).”
Ivanhoe v. United States, No. 3:20-cv-00148 (D. Conn. July 28, 2022).
· cites it 2× “” 26 U.S.C. §6222 (a). “[I]f a partner treats items inconsistently with the partnership’s treatment of those items, a deficiency may be assessed against the partner without notice, as a ‘computational adjustment.”
Latitude Serv. Co. v. Reese, No. 3:21-cv-00728 (N.D. Ind. Nov. 18, 2022).
“Moreover, although Latitude points out that 26 U.S.C. §§ 6222 (c) and 6037(c) provide a remedy for situations where a partner or a shareholder takes an inconsistent position with the company’s tax return,4 Mr.”
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