Legal Opinion
Linda Romano-Murphy v. Commissioner of IRS
Court of Appeals for the Eleventh Circuit
Decided March 7, 2016No. 13-13186PublishedCited by 21 opinions
1Opinion of the Court
JORDAN, Circuit Judge:
Learned Hand and John Minor Wisdom, two of our most venerated jurists, described the Internal Revenue Code as a labyrinth. See Branum v. Commissioner, 17 F.3d 805, 808 (5th Cir.1994) (Wisdom, J.); Learned Hand, Thomas Walter Swan, 57. Yale L. Rev. 167, 169 (1947). After laboring on this tax appeal for a while, we can understand why.
Two questions, both of a procedural nature, confront us. The first one, which appears to be a matter of first impression, is whether the existing statutory and regulatory framework entitles a taxpayer to a pre-assessment determination of her…
2Cases cited36 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Morton v. RuizSupreme Court of the United States · 1974
- Service v. DullesSupreme Court of the United States · 1957
- Hibbs v. WinnSupreme Court of the United States · 2004
31 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Lindell Washington v. Commissioner of Social SecurityCourt of Appeals for the Eleventh Circuit · 2018
- Douglas Bourdon v. United States Department of Homeland SecurityCourt of Appeals for the Eleventh Circuit · 2019
- United States v. Said RumCourt of Appeals for the Eleventh Circuit · 2021
- Douglas Bourdon v. United States Department of Homeland SecurityCourt of Appeals for the Eleventh Circuit · 2020
- Alan M. Berkun v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2018
16 more not listed; retrieve them via the Exa API.