Legal Opinion
Douglas E. Wall v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided May 30, 1989No. 87-2684PublishedCited by 10 opinions
1Opinion of the Court
LOGAN, Circuit Judge.
Petitioner Douglas E. Wall appeals from a decision of the United States Tax Court holding that the Commissioner of Internal Revenue was not barred from issuing Wall a notice of deficiency almost six years after Wall had executed Form 872-A, an indefinite waiver of the three-year limitations period on income tax assessments. See I.R.C. § 6501(a). The sole issue on appeal is whether the Commissioner should be es-topped to assess the deficiency in this case for making it within an allegedly unreasonable period of time after Wall executed Form 872-A.
The facts are not in…
2Cases cited3 opinions
- McManus v. CommissionerCourt of Appeals for the Ninth Circuit · 1978
- Estate of Camara v. CommissionerUnited States Tax Court · 1988
- Stenclik v. CommissionerUnited States Tax Court · 1989
3Cited by10 opinions
- Mecom v. CommissionerUnited States Tax Court · 1993
- Richard R. Stenclik and Dolores Stenclik v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1990
- Robert M. St. John, Margaret E. St. John v. United States of America, Robert M. St. John, Margaret E. St. John v. United StatesCourt of Appeals for the Ninth Circuit · 1991
- Silverman v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1996
- Bilski v. CommissionerUnited States Tax Court · 1994
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