Ralph Harold Harbold v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
MILBURN, Circuit Judge.
Petitioner appeals the Tax Court’s order denying his motion for special leave to file a motion to vacate its decision-and to withdraw stipulations entered in this tax liability case. We have jurisdiction over appeals from the Tax Court pursuant to I.R.C. § 7482(a). On appeal, the issue is whether the Tax Court had jurisdiction to consider petitioner’s motion for special leave to file a motion to vacate its decision and to withdraw stipulations where the underlying decision had become final because more than 90 days had lapsed since the decision was entered. For the…
2Cases cited25 opinions
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Borden's Farm Products Co. v. BaldwinSupreme Court of the United States · 1934
- Freytag v. CommissionerUnited States Tax Court · 1987
- Commissioner v. McCoySupreme Court of the United States · 1987
- Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
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3Cited by34 opinions
- Desmet v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2009
- Sheldon Drobny and Anita Drobny v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1997
- John W. Roberts, Cheryl W. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1999
- Computer Leasco, Inc. v. NTP, Inc.Court of Appeals for the Sixth Circuit · 2006
- Davenport Recycling Associates v. CommissionerCourt of Appeals for the Eleventh Circuit · 2000
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