Legal Opinion
Estate of Ray v. Commissioner
Court of Appeals for the Fifth Circuit
Decided May 8, 1997No. 96-60322PublishedCited by 4 opinions
1Opinion of the Court
STEWART, Circuit Judge:
Taxpayers appeal the tax court’s decision that the Commissioner of Internal Revenue Service’s (IRS) notices of deficiency were not time-barred. The IRS assessed deficiencies in income taxes as to appellants’ taxable years 1983 and 1984, one year after it execut ed .a settlement agreement with taxpayers. Taxpayers assert that the one-year statute of limitations was triggered when they signed the settlement agreement, and thus the IRS’s assessment was time-barred. For the following reasons, we affirm.
BACKGROUND
The facts are undisputed. During the relevant time period,…
2Cases cited5 opinions
- Federal Deposit Insurance v. McFarlandCourt of Appeals for the Fifth Circuit · 1994
- Treaty Pines Investments Partnership v. Commissioner Of Internal RevenueCourt of Appeals for the Fifth Circuit · 1992
- Gillilan v. CommissionerUnited States Tax Court · 1993
- Haiduk v. CommissionerUnited States Tax Court · 1990
- Brookstone Corp. v. United StatesCourt of Appeals for the Fifth Circuit · 1995
3Cited by4 opinions
- Frank W. Smith Janice M. Smith v. United StatesCourt of Appeals for the Fifth Circuit · 2003
- Equal Employment Opportunity Commission v. Federal Express Corp.District Court, E.D. New York · 2003
- Gregory v. United StatesDistrict Court, S.D. Texas · 2000
- Smith v. United StatesCourt of Appeals for the Fifth Circuit · 2003