Bufferd v commissioner

COMMISSIONER OF INTERNAL REVENUE Justice White, delivered the opinion of the Court.

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Phyllis Bufferd settled separately with the Commissioner and is not a party to this action.

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On his 1979 income tax return, petitioner, a shareholder in a.

Stokes v. Commissioner (Private Annuity Trust Case)

Because of these considerations, and because Bufferd did not press this argument on appeal, even after a request for additional briefing on the issue by this Court, we do not reach that issue.The sole issue on appeal is whether the Commissioner of Internal Revenue (Commissioner) timely assessed the deficiency.

At oral argument, the Commissioner maintained that the opposite is the case, see Tr. of Oral Arg. 27-28, relying mainly on Commissioner v.Commissioner - Response (Acquiescence) Docket number: No. 99-1295. As this Court explained in Bufferd v.

Davis v. Commissioner (2:16-cv-11601), Michigan Eastern

That Compo erroneously asserted a loss and credit to be passed through to its shareholders is of no consequence.COHEN v. COMMISSIONER OF THE DIVISION OF MEDICAL ASST 668 N.E.2d 769 (Mass. 1996) MARY COHEN vs.Section 6037 therefore retains ample meaning even bereft of the interpretation proposed by Bufferd.In fact, Bufferd arguably waived this argument through the stipulations filed before the tax court.


COMMISSIONER OF INTERNAL REVENUE on writ of certiorari to the united states court of appeals for the second circuit.

Commissioner, 506 U.S. 523, 527 n.6 (1993) (citing Badaracco v.The Commissioner claims that that term refers to the return of the taxpayer against whom the Commissioner has imposed the deficiency.COMMISSIONER OF INTERNAL REVENUE. No. 91-7804. Argued Nov. 30, 1992. Decided Jan. 25.

List of United States Supreme Court cases, volume 506

The statute accomplishes these goals by means of a pass-through system under which corporate income, losses, deductions, and credits are attributed to individual shareholders in a manner akin to the tax treatment of partnerships.

Compo Financial Services, Incorporated, was not a partnership and Bufferd did not treat it as a partnership on his 1979 joint return.Bufferd ultimately agreed to the deficiency assessed by the Commissioner to the extent of the disallowance of the direct partnership loss.

Commissioner (Appeal - Full Text) Thank you for visiting Business Valuation Resources, the leading provider of.Section 6037(a) thus originally functioned to set the starting date of the 3-year period within which that determination had to be made.Commissioner, including the facts, issue, rule of law, holding and reasoning, key terms, and concurrences and dissents.Commissioner, --- U.S. ----, 113 S.Ct. 927, 122 L.Ed.2d 306 (1993). 7.Audio Transcription for Oral Argument - November 30, 1992 in Bufferd v.

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The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader.

The Tax Court found for the Commissioner, relying on its decision in Fehlhaber v.To disallow those items, petitioner argues, the Commissioner must have acted within three years of the filing of the corporate return.

Teleservice Company of Wyoming Valley, Petitioner, V


In this case, the errors on the corporate return did not and could not affect the tax liability of the corporation, and hence the Commissioner could only assess a deficiency against the stockholder-taxpayer whose return claimed the benefit of the errors.Commissioner, 963 F.2d 783 (CA5 1992), neatly summarizes the appropriate response to that concern.

Whether the election by the shareholders of V & M

Thus the tax court ordered Bufferd to pay the full amount of the deficiency.The Controversy Over the Application of the Statute of Limitations to S Corporations and. Bufferd v.

In March 1983, before three years had passed from the time the joint return was filed, petitioner agreed to extend the period in which deficiencies arising from certain claims on the return could be assessed against him.Bufferd and his wife filed a joint income tax return in 1979.

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4 F3d 709 Wolf v. Commissioner Internal Revenue Service

That section bars only the assessment of a tax on an entity more than three years after the entity has filed a return.Commissioner, 77 T.C.M. 2206, T.C.M. (RIA) 99,204 (Tax Ct. 1999) United States Tax Court. R. SCOT STOKES, Petitioner. v. COMMISSIONER OF INTERNAL REVENUE.Filler, University of Bridgeport School of Law Tax Clinic, Bridgeport, Conn. (Toni Robinson, Joseph A.

Tax Digest - Pugh CPAs

Solicitor-Client Privilege Trumps the Privacy. the Supreme Court released its judgment in Canada (Privacy Commissioner) v. Foster Wheeler Power Co. v.United States, 801 F.Supp. 718, 721 (ND Ga.1992). 10 corporation must make a return for each taxable year in accordance with new section 6037. Such return will be considered as a return filed under section 6012 for purposes of the provisions of chapter 66, relating to limitations.DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224. In Lardas v.Commissioner of Internal Revenue. U.S. Supreme Court Transcript of Record with Supporting Pleadings.Section 6037(a) was introduced in the Technical Amendments Act of 1958, 72 Stat. 1606, 1656.Commissioner, 353 U.S. 180, 188, 77 S.Ct. 707, 712, 1 L.Ed.2d 746 (1957) (citing Commissioner v.Compo never assented to an extension of time to assess the tax due for 1979.