Legal Opinion
Charles and Marion Hefti v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided March 26, 1990No. 89-1302PublishedCited by 6 opinions
1Opinion of the Court
FLOYD R. GIBSON, Senior Circuit Judge.
Charles and Marion Hefti appeal the tax court’s1 dismissal of their case for failure to comply with orders of that court. We vacate the judgment and remand for determination of whether Treas. Reg. § 301-7609-5(b) exceeds the congressional authorization in I.R.C. § 7609(e).
I. BACKGROUND
A. The Dismissal
The Heftis received a statutory notice of deficiency from the Commissioner of Internal Revenue (the “Commissioner”) on December 7, 1987, for deficiencies in the tax years 1983, 1984, and 1985. In March 1988, the Heftis filed petitions in the tax court seeking…
2Cases cited9 opinions
- Hiram Ash v. Eugene CvetkovCourt of Appeals for the Ninth Circuit · 1984
- Douglas M. Hart v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1984
- United States v. Victor F. OrlowskiCourt of Appeals for the Eighth Circuit · 1987
- DuBose v. MinnesotaCourt of Appeals for the Eighth Circuit · 1990
- United States v. Thore P. MeyerCourt of Appeals for the Eighth Circuit · 1987
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Advantedge Business Group, LLC v. Thomas E. Mestmaker & Associates, Inc.Court of Appeals for the Tenth Circuit · 2009
- Charles Hefti Marion Hefti v. Commissioner of Internal Revenue of the United States of AmericaCourt of Appeals for the Eighth Circuit · 1993
- Hefti v. CommissionerUnited States Tax Court · 1991
- Charles and Marion Hefti v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
- Hefti v. CommissionerUnited States Tax Court · 1993
1 more not listed; retrieve them via the Exa API.