Legal Opinion
Green v. Commissioner
Court of Appeals for the Fifth Circuit
Decided June 19, 1992No. 90-4629 to 90-4632, 90-4847 to 90-4853, 90-4881 and 91-4497PublishedCited by 9 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
The statute of limitations in section 6501 of the Internal Revenue Code declares that “the amount of any tax imposed by this title shall be assessed within 3 years after the return was filed.” 26 U.S.C. § 6501(a). 1 A Subchapter S corporation makes a return for a taxable year and, more than three years after the S corporation files its return, the Commissioner of Internal Revenue seeks to assess a deficiency against a shareholder of that S corporation for certain losses passed through from the S corporation to the shareholder, within three years after the shareholder…
2Cases cited13 opinions
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- E. I. Dupont De Nemours & Co. v. DavisSupreme Court of the United States · 1924
- John A. Sage v. United StatesCourt of Appeals for the Fifth Circuit · 1990
- Siben v. CommissionerCourt of Appeals for the Second Circuit · 1991
8 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Bufferd v. CommissionerSupreme Court of the United States · 1993
- Robinson v. Comm'rUnited States Tax Court · 2001
- Keech v. CommissionerUnited States Tax Court · 1993
- Charles T. Green and Kay E. Green v. Commissioner of Internal Revenue, Robert White and Jean R. White v. Commissioner of Internal Revenue, Robert White and Jean R. White v. Commissioner of Internal Revenue, Gene C. Elkins and Louise Elkins v. Commissioner of Internal Revenue, R. Talley and Carolyn Melton v. Commissioner of Internal Revenue, Norman C. Way and Mary K. Way v. Commissioner of Internal Revenue, Bobby L. And Ramona A. Davis v. Commissioner of Internal Revenue, James R. And Elizabeth J. Graves v. Commissioner of Internal Revenue, Don C. And Audrey N. Quast v. Commissioner of Internal Revenue, Elizabeth C. Mayfield v. Commissioner of Internal Revenue, Jack E. And Jeanne Blanco v. Commissioner of Internal Revenue, Mike and Sandra Ann Kane v. Commissioner of Internal Revenue, Martin Brody and Jerrilyn Brody v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1992
- Oliver K. Robinson and Deborah L. Robinson v. CommissionerUnited States Tax Court · 2001
4 more not listed; retrieve them via the Exa API.