Thompson v. Commissioner, No. 15-2329 (8th Cir. 2016)
Annotate this CaseThe IRS disallowed all deductions and losses reported by RJT on its 2001 partnership return. It also determined that a 40-percent accuracy-related penalty for gross misstatement of partnership basis would be applied to any underpayment of tax by RJT partners resulting from the adjustments made to the RJT partnership return. RJT and Thompson challenged these adjustments in a partnership-level proceeding before the Tax Court, but the adjustments, including imposition of the penalty, were affirmed by the Tax Court and by this court on appeal. Then the Thompsons filed a petition in the Tax Court to challenge both the tax deficiency and the penalty. The IRS contends that the Thompsons are prohibited from challenging the Tax Court’s jurisdiction over the penalty issue under the law-of-the-case doctrine. The court affirmed the judgment, concluding that the Tax Court did not err by dismissing the penalty issue for lack of jurisdiction.
Court Description: Wollman, Author, with Melloy and Colloton, Circuit Judges] Tax Court. The Tax Court did not err in dismissing the taxpayers' challenge to the penalty issue in the case for lack of jurisdiction as they had withdrawn their challenge to the penalty issue earlier in the litigation and the matter had become moot. [ May 02, 2016
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