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Tax Court upholds timeliness of 2018 affected-items notices to Tom Gonzales

Gonzales v. Commissioner, T.C. Memo. 2025-103, No. 3361-19., 2025 BL 361489, Court Opinion

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Tax Coda
Oct 23, 2025
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On October 8, 2025, the U.S. Tax Court granted the IRS’s motion for partial summary judgment in Gonzales v. Commissioner, holding that three November 16, 2018 affected-items notices of deficiency for 2000, 2001, and 2003 were timely.

The court found the limitations issue already resolved at the partnership level and, in any event, precluded by collateral…

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