Attorney-at-Law

“TIME IS ON MY SIDE – YES IT IS” – PART DEUX

In Uncategorized on 07/22/2016 at 16:39

A reader pointed out that the T.C. I blogged yesterday, CGG Americas, Inc., 147 T. C. 2, filed 7/21/16, apparently took four (count ‘em, four) years to write. I hadn’t done a docket search, but when I looked just now, the Tax Court docket showed the last entry as 10/17/12, and the case was filed 11/12/10. So the opinion took roughly four years from when the last papers were filed, and six years from when the case was filed.

I asked the reader “how if the taxpayer owed the deficiencies, with interest running?” Rhetorical, of course, in this case, as taxpayer won.

But it brought back memories of poor Beverly Bernice Bang. See my blogpost “Bang – A Warning to Tax Matters Partners (and their advisors).” 1/5/11.

And just today Big Julie, His Honor Judge Julian I Jacobs (hereinafter “HHBJJJIJ”), has another example.

It’s a one page designated hitter, BC/Falcon Coconut Creek, LLC, BC Coconut Creek, LLC, Tax Matters Partner, Docket No. 19037-12, filed 7/22/16.

“Respondent’s counsel requested that the Court set a trial date for this case. Petitioners counsel did not object but requested that the case not be set for trial for at least a year.” Order, at p. 1.

OK, says HHBJJJIJ, try it in November 2017.

And if the interest is running, someone is in for a shock if they lose.

Advertisements

Leave a Reply

Please log in using one of these methods to post your comment:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s

%d bloggers like this: