Memorandum Opinion
GERBER, Judge.
We are asked to consider whether the period for assessment had expired at the time the Commissioner had issued and mailed the notice of final partnership administrative adjustment (FPAA) as to the partnership. More specifically, we must decide whether a properly authorized person executed the consent to extend the assessment period. The parties address the issue in two different contexts. First, we consider whether the person...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.