Legal Opinion
Ramon Portillo and Dolores Portillo v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided June 11, 1991No. 90-4343PublishedCited by 125 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
Ramon Portillo appeals from the Tax Court’s rejection of his challenge to a notice of deficiency from the Internal Revenue Service (the “I.R.S.”). Portillo initially argues that the simple computerized matching of Portillo’s employer's Form 1099 with Portillo’s Form 1040 was not a “determination” as required by section 6212(a) of the Internal Revenue Code (the “Code”). We reject this argument, finding that the I.R.S. adequately linked Portillo to the alleged deficiency. We do agree with Portillo, however, that the notice of deficiency was arbitrary and erroneous…
2Cases cited25 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Elkins v. United StatesSupreme Court of the United States · 1960
- United States v. JanisSupreme Court of the United States · 1976
- Helvering v. TaylorSupreme Court of the United States · 1935
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
20 more not listed; retrieve them via the Exa API.
3Cited by125 opinions
- Donald R. Ferguson v. United States v. Richard Musal, Third Party Nicholas P. Miller, Third PartyCourt of Appeals for the Third Circuit · 2007
- Cathy Miller Hardy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- Robinson v. CommissionerUnited States Tax Court · 1994
- Powers v. CommissionerUnited States Tax Court · 1993
- Charlotte's Office Boutique, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
120 more not listed; retrieve them via the Exa API.