United States Supreme Court

The proper tax assessment against a partnership suffices to extend the statute of limitations to collect the tax in a judicial proceeding from the general partners who are liable for the payment of the partnership's debts. Once a tax has been properly assessed, nothing in the Internal Revenue Code requires the IRS to separately assess the same tax against individuals who are not the actual taxpayers but are, by reason of state law, liable for the taxpayer's debt.

Appellate Information

• Decided 03/23/2004
• Published 03/23/2004

Judges

Court

• United States Supreme Court

Counsel