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CHAI v. COMMISSIONER OF INTERNAL REVENUE

No. 13213-10.

T.C. Memo. 2011-273

JASON CHAI, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 17, 2011.

Attorney(s) appearing for the Case

Frank Agostino and Jeremy M. Klausner , for petitioner.

Alan M. Jacobson , for respondent.

MEMORANDUM OPINION

KROUPA, Judge.

This matter is before the Court on respondent's motion for partial summary judgment filed pursuant to Rule 121.1 Respondent asks this Court to decide, as a matter of law, that the statute of limitations does not bar assessment of tax attributable to certain partnership items of Jason Chai (petitioner) that were converted to nonpartnership items for 2003. Our decision turns on whether petitioner...

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