Legal Opinion
Charles E. Hubbard v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 12, 1989No. 88-1390PublishedCited by 10 opinions
1Per curiam
During each of the years 1976, 1977, 1978, and 1979, Charles Hubbard filed federal income tax returns in which he held a partnership interest in a tax shelter. He claimed loss deductions and investment credits with respect to the shelter on each return. After the returns were filed with the Internal Revenue Service (IRS), they were audited by the District Director in Detroit, Michigan.
Section 6501(a) of the I.R.C. generally requires the IRS to assess any deficiency in tax within three years after the return for the year in question has been filed. The limitations period may be extended,…
2Cases cited5 opinions
- Joseph Policy William Driscoll John Chufo v. The Powell Pressed Steel CompanyCourt of Appeals for the Sixth Circuit · 1985
- Richard L. Mulvania v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Louis E. Roszkos and Vivian L. Roszkos v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Roszkos v. CommissionerUnited States Tax Court · 1986
- Hubbard v. Comm'rUnited States Tax Court · 1987
3Cited by10 opinions
- Patmon and Young Professional Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1995
- Coffey v. CommissionerUnited States Tax Court · 1991
- Michael J. Berman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
- Eloise Kirby Taylor v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1994
- Carnahan v. CommissionerUnited States Tax Court · 1991
5 more not listed; retrieve them via the Exa API.