United States Ninth Circuit
Meruelo v. Comm'r of Internal Revenue, 11-70015
Tax Court's denial of petitioners' motion to dismiss for lack of jurisdiction is affirmed, as the IRS issued the Notice of Deficiency when there was no pending partnership-level proceeding, no notice of final partnership administrative adjustment had been issued, and the normal three-year statute of limitations in section 6229(a) expired a few days later.
Appellate Information
- Decided 08/16/2012
- Published 08/16/2012
Judges
- Smith
Court
- United States Ninth Circuit