Peters & Assoc., Certified Pub. Accountants, P.C. v. Upcraft

How courts have described this case

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

• holding that when the IRS simply has to perform mathematical calculations--i.e., plug numbers into a formula--to determine a partner's tax liability, it is a computational adjustment that does not require further determinations at the partner level
• holding that when the IRS simply has to perform mathematical calculations — i.e., plug numbers into a formula — to determine a partner’s tax liability, it is a computational adjustment that does not require further determinations at the partner level
• acknowledging that “Our holding that the assessments in this case meet the definition of ‘computational adjustment’ under I.R.C. § 6231(a)(6
• “Nothing about this regulation requires that a computational adjustment involve a change in treatment of a partnership item. While it shows that a computational adjustment may (and often does
• referring to partnership items as “items whose treatment affects the entire partnership”

Source: CourtListener parenthetical corpus (CC0).