Case: Court Upholds IRS’s Computational Adjustments, Penalties Against Taxpayers in Disallowing Partnership Loss (IRC §6230)

The U.S. District Court for the Middle District of Florida granted summary judgement against the taxpayers, holding that the IRS properly made computational adjustments to the taxpayers’ returns without issuing a notice of deficiency, and that the taxpayers’ were not entitled to relief from penalties. The taxpayers, a married couple, had claimed partnership losses from an entity in which the husband was determined not to be a partner. The taxpayers filed a complaint in the District Court against the U.S. government seeking a refund of income tax and penalties for tax years 2015-2018. Upon summary judgment review, the District Court ...