Abel Kaplan and Mary Lou Kaplan v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that district court lacked subject matter jurisdiction, in individual tax partner’s refund challenge, to consider statute of limitations argument
• “Section 6226(c) binds all partners to the result obtained by a legal challenge brought by one partner, thereby preventing numerous [duplicative] lawsuits.”
• “Section 6226(c) binds all partners to the result obtained by a legal challenge brought by one partner, thereby preventing numerous [duplicative] lawsuits.”
• “TEFRA requires that all challenges to adjustments of partnership items be made in a single, unified agency-proceeding; indeed, this is the key component of TEFRA that yields the desired benefits of economy and consistency.”
• subtitle F provisions involving authority of TMP may be considered partnership item
• “TEFRA ... establishes] procedures for disseminating information regarding the taxation of partnership items____ I.R.S. must provide notice to each partner of any adjustments to partnership items. This notice takes the form of a final partnership administrative adjustment (FPAA

Source: CourtListener parenthetical corpus (CC0).