Legal Opinion
United States v. Leroy J. Jenkins, and Ann Jenkins
Court of Appeals for the Fifth Circuit
Decided January 15, 1986No. 85-1114PublishedCited by 13 opinions
1Per curiam
I
In August 1976, taxpayers Leroy J. and Ann M. Jenkins were notified of deficiencies for the tax years 1972 through 1974. On November 26, 1976, a letter was filed in the United States Tax Court. The letter, which was captioned “PETITION,” stated: “I hereby PROTEST your Notice of Decici-ency [sic] dated Aug. 24, 1976 Ident. No: DD:Dallas:A:S:90-D:306.” Beneath this sentence were Leroy Jenkins’ signature and the typewritten names of both Leroy and Ann Jenkins.
The Tax Court determined that this document did not comply with court rules fixing the form and content of a proper petition and…
2Cases cited3 opinions
- John F. Finley, of the Estate of Mildred B. Whitlock v. United StatesCourt of Appeals for the Fifth Circuit · 1980
- Robert M. Crandall v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
- United States v. Vera R. Maxwell, and Hugh Stanton Parker, Etc.Court of Appeals for the Fifth Circuit · 1972
3Cited by13 opinions
- Richard D. Bokum, Ii, Margaret B. Bokum v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
- James Coleman v. Lincoln Parish Detention Ctr, etCourt of Appeals for the Fifth Circuit · 2017
- United States v. BarrettoDistrict Court, S.D. New York · 1989
- Johnson v. WatkinsDistrict Court, S.D. Mississippi · 2011
- Estate of Scott C. Ronning, Harlan L. Paul, Personal Representative v. CommissionerUnited States Tax Court · 2019
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