Legal Opinion
Tolve v. Commissioner IRS
Court of Appeals for the Third Circuit
Decided March 25, 2002No. 00-2289UnknownCited by 3 opinions
1Opinion of the Court
OPINION
RENDELL, Circuit Judge.
This appeal comes to us from the Tax Court’s grant of summary judgment in favor of the Internal Revenue Service (“IRS”). At the heart of this appeal is the Tax Court’s refusal to permit the taxpayers, Richard and Bette Tolve, to withdraw their deemed admissions and to amend their pleadings so as to raise a statute of limitations defense as to the IRS’s claim for additions to tax and interest. They claim that the consent form only waived the statute of limitations regarding the amount of the tax itself, and also that the statute of limitations had run regarding…
2Cases cited10 opinions
- Martin O. Washington v. Philadelphia County Court of Common Pleas, Martin WashingtonCourt of Appeals for the Third Circuit · 1996
- Stange v. United StatesSupreme Court of the United States · 1931
- 999, a Corporation, Plaintiff/appellee/cross-Appellant v. C.I.T. Corporation, a Corporation, Defendant/appellant/cross-AppelleeCourt of Appeals for the Ninth Circuit · 1985
- Kronish v. CommissionerUnited States Tax Court · 1988
- Eldon D. And Kathy A. Anthony v. United StatesCourt of Appeals for the Tenth Circuit · 1993
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3Cited by3 opinions
- In Re BrownDistrict Court, E.D. Pennsylvania · 2004
- United States v. Inn Foods, Inc.United States Court of International Trade · 2003
- Estate of Greenfield v. Comm'rUnited States Tax Court · 2008