Court explained in Bufferd v. Commissioner, 506 U.S. 523, 525 (1993), Subchapter S of the Code implements "a pass-through system under which corporate income, losses, deductions, and credits are attributed to individ-ual shareholders in a manner akin to the tax treatment of partnerships." In 1992, these two Subchapter S corporations became
Bufferd v. Commissioner, 506 U.S. 523, 525 (1993). This can be illustrated by example. If petitioners had hired a third party to perform the officer duties that they performed, and they paid that third party an amount equal to that included as See IRC section 6501; Bufferd v. Commissioner , 506 U.S. 523 (1993). Accordingly, any extension of the statute of limitations for adjustments proposed to the pass-through entity's returns must be protected by securing a statute extension from each investor in the pass-through entity. "Bufferd v. Commissioner of Internal Revenue." Oyez, www.oyez.org/cases/1992/91-7804. Accessed 18 Jul. 2020. See Bufferd v. Commissioner, 506 U. S. 523, 525 (1993). The corporation's profits pass through directly to its shareholders on a pro rata basis and are reported on the shareholders' individual tax returns.
4The issue of which return is referred to in section 6501(a) was settled in Bufferd v. Commis- Commis- sioner, 113 S. Ct. 927 (1993), which held that the return referred to in section 6501(a) is the return
Sheldon Bufferd appeals from a decision of the United States Tax Court imposing a tax deficiency on him for the year 1979. The sole issue on appeal is whether the Commissioner of Internal Revenue (Commissioner) timely assessed the deficiency. MESKILL, Circuit Judge: Sheldon Bufferd appeals from a decision of the United States Tax Court imposing a tax deficiency on him for the year 1979. The sole issue on appeal is whether the Commissioner of Internal Revenue (Commissioner) timely assessed the deficiency. MESKILL, Circuit Judge: Sheldon Bufferd appeals from a decision of the United States Tax Court imposing a tax deficiency on him for the year 1979. The sole issue on appeal is whether the Commissioner of Internal Revenue (Commissioner) timely assessed the deficiency. See Bufferd v. Commissioner, 506 U. S. 523, 525 (1993). The corporation's profits pass through directly to its shareholders on a pro rata basis and are reported on the shareholders' individual tax returns.
Bufferd v. Commissioner of Internal Revenue. Continued. Atlantic Mutual Insurance Company v. Commissioner of Internal Revenue. The Internal Revenue Code allowed
1 More precisely, the “quid pro quo” element of the FCPA’s anti-bribery prohibitions encompasses payments “for purposes of”: (a) “influencing any act or decision of such foreign official in his official capacity,” (b) inducing such Following Bufferd v. Commissioner, 506 U.S. 523 (1993), the three year assessment period under § 6501 runs from the date of the shareholder's filing of its individual return. This was codified by Title U.S. Reports: Paulsen v. Commissioner, 469 U.S. 131 (1985). Contributor Names Rehnquist, William H. (Judge) According to the US Supreme Court in Bufferd v. Commissioner, 506 U.S. 523, 524-25 (1993), "Subchapter S of the Internal Revenue Code, 26 U.S.C. §§ 1361-1379, was