Clark v. Commissioner: Tax Court’s Summary Judgment on Limitation Period of FPAA Affirmed

In Clark v. Commissioner, the Court of Appeals for the Ninth Circuit affirmed the Tax Court’s summary judgment because the IRS’s final partnership administrative adjustment (FPAA) of an entity’s partnership return for a tax year at issue was issued outside of the applicable three-year limitation period. The taxpayer’s motion for summary judgment with respect to an untimely notice of FPAA was granted.

See full opinion at Clark v. Commissioner. 

Posted by Jessica Ji, Associate Editor, Wealth Strategies Journal.