Legal Opinion

Ellen v. Erhard v. Commissioner Internal Revenue Service

Court of Appeals for the Ninth Circuit

Decided June 20, 1996No. 94-70749PublishedCited by 19 opinions

1Opinion of the Court

CYNTHIA HOLCOMB HALL, Circuit Judge:

Ellen Erhard appeals the Tax Court’s dismissal of her petition as untimely filed. We affirm.

I

Ellen and Werner Erhard filed joint tax returns for the 1984, 1985, 1986, 1987, and 1988 tax years. When they divorced, Ellen executed a power of attorney appointing Werner as her attorney-in-fact and authorizing him to act on her behalf regarding the 1984, 1985, and 1986 tax years. Werner, in turn, executed a second power of attorney authorizing New York attorney Michael Saltzman to act on behalf of him and Ellen for the 1984, 1985, 1986, and 1987 tax years…

2Cases cited7 opinions

  1. Pyo v. CommissionerUnited States Tax Court · 1984
  2. Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
  3. Gregory W. McKay v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
  4. Lloyd E. Latch and Constance A. Latch v. United States of America, and Does I Through X, InclusiveCourt of Appeals for the Ninth Circuit · 1988
  5. Richard L. Mulvania v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985

2 more not listed; retrieve them via the Exa API.

3Cited by19 opinions

  1. Sego v. CommissionerUnited States Tax Court · 2000
  2. Reliance Insurance v. Mast Construction Co.Court of Appeals for the Tenth Circuit · 1998
  3. UMG Recordings, Inc. v. SinnottDistrict Court, E.D. California · 2004
  4. Committee on Grievances of the United States District Court for the Eastern District of New York v. Roger Bruce FeinmanCourt of Appeals for the Second Circuit · 2001
  5. Bonedaddy's of Lee Branch, LLC v. City of BirminghamSupreme Court of Alabama · 2015

14 more not listed; retrieve them via the Exa API.

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