Legal Opinion
Harry Holof and Norma Holof v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided April 12, 1989No. 88-1185PublishedCited by 18 opinions
1Opinion of the Court
OPINION OF THE COURT
SCIRICA, Circuit Judge.
In this appeal we must decide whether a defective notice of tax deficiency mailed by the Internal Revenue Service terminates taxpayers’ Form 872-A consent to waive the statute of limitations on assessment of tax deficiencies. The Commissioner ap peals from the Tax Court’s decision upholding the termination of the limitations waiver and barring the IRS from assessing the additional taxes owed.
We hold that: (1) Form 872-A must be read in conjunction with the statutory provisions on tax assessment; (2) Form 872-A contemplates termination only by an…
2Cases cited14 opinions
- Universal Minerals, Inc. v. C. A. Hughes & Co.Court of Appeals for the Third Circuit · 1981
- Mellon Bank, N.A. v. Aetna Business Credit, Inc.Court of Appeals for the Third Circuit · 1980
- Florsheim Brothers Drygoods Co. v. United StatesSupreme Court of the United States · 1930
- Stange v. United StatesSupreme Court of the United States · 1931
- Joseph Delman and Jeanette Delman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
9 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- United States v. L. Robert Frame, Sr. And Vintage Sales Stables, Inc.Court of Appeals for the Third Circuit · 1989
- Philadelphia & Reading Corporation v. United StatesCourt of Appeals for the Third Circuit · 1991
- Albert E. Robinson and Rose M. Robinson v. United StatesCourt of Appeals for the Third Circuit · 1991
- Ronald C. Bachner v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Third Circuit · 1996
- Terrell v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
13 more not listed; retrieve them via the Exa API.