deficiency

What Is The United States Tax Court And What Happens When The Tax Court Hears A Case?

The United States Tax Court is a federal trial court established by Congress under Article I of the U.S. Constitution, section 8. The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. The U.S. Tax Court is not an agency of, and is independent of, the executive branch. The U.S. Tax Court is the only forum in which taxpayers may file a case without having first paid the disputed tax in full. Tax Court judges are appointed for a term of 15 years, subject to presidential removal for actions related to neglect, inefficiency, or malfeasance.

Relating to the allocation of partnership liabilities and the tax implication of a foreclosure

Issue

What is the allocation of partnership liabilities and the tax implication of a foreclosure?

Related Tax Rule or Regulation

Internal Revenue Code Section 465

Internal Revenue Code Section 704

Internal Revenue Code Section 731

Internal Revenue Code Section 752

Internal Revenue Code Section 1001

Tax Regulation § 1.1001-2(c),

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