Legal Opinion
Richard L. Abrams v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided April 14, 1987No. 85-7526PublishedCited by 40 opinions
1Per curiam
Petitioner Richard Abrams and 33 other taxpayers appeal the United States Tax Court’s dismissal of their consolidated petition for redetermination of tax deficiencies for the year 1983, 84 T.C. 1308. The only issue we decide is whether the Tax Court correctly dismissed the petition for lack of jurisdiction on the basis that a prefiling notification letter was not a notice of deficiency. We affirm.
The Internal Revenue Service (IRS) sent Abrams a letter, 1 known as a pre-filing notification, advising him that the tax shelter in which he had invested was not a proper basis for tax deductions or…
2Cases cited11 opinions
- Laing v. United StatesSupreme Court of the United States · 1976
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
- Commissioner of Internal Revenue v. StewartCourt of Appeals for the Sixth Circuit · 1951
- Jeremiah Benzvi and Robert L. McLeroy v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
- Abrams v. CommissionerUnited States Tax Court · 1985
6 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Ronnie O. Kitchens v. Otis R. BowenCourt of Appeals for the Ninth Circuit · 1987
- Washington Trout v. McCain Foods, Inc.Court of Appeals for the Ninth Circuit · 1995
- Bourekis v. Comm'rUnited States Tax Court · 1998
- Hubbard v. CommissionerUnited States Tax Court · 1987
- Dorothy Smith v. United StatesCourt of Appeals for the Ninth Circuit · 1989
35 more not listed; retrieve them via the Exa API.