Gaughf Properties, L.P. v. Commissioner, IRS

Appellants appealed the tax court's decision, holding that the period to assess taxes for tax year 1999 against Jack Gaughf and his wife remained open as of March 30, 2007, when the IRS issued a Notice of Final Partnership Administrative Adjustment (FPAA) to Gaughf Properties, L.P. The court affirmed the tax court's holding that (1) the Gaughfs' tax liability came within the unidentified partner exception to the general three-year statute of limitations under I.R.C. section 6229(e) because the Gaughfs were not identified as indirect partners to Gaughf Properties, L.P. in its 1999 return and (2) information identifying them as indirect partners was not otherwise timely furnished to the Secretary of the Treasury so as to trigger the one-year limitation period in I.R.C. section 6229(e). View "Gaughf Properties, L.P. v. Commissioner, IRS" on Justia Law