Legal Opinion
Pesko v. United States
United States Court of Claims
Decided March 9, 1990No. 410-89TPublishedCited by 4 opinions
1Opinion of the Court
OPINION
BRUGGINK, Judge.
The issue presented by this action is whether the Internal Revenue Service (“IRS”) timely assessed plaintiffs for their 1970 income tax deficiency. The matter is before the court on defendant’s motion to dismiss and plaintiffs’ motion for summary judgment. After consideration of the record, the parties’ argument, and the applicable law, defendant’s motion is granted.
*688. BACKGROUND FACTS
The relevant facts are undisputed. On or about April 15, 1971 the Peskos timely filed a joint tax return for the 1970 calendar year. The Peskos executed a series of consents to extensions…
2Cases cited7 opinions
- Albert White and Vivian B. White v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Security Industrial Insurance Company v. United States of AmericaCourt of Appeals for the Fifth Circuit · 1987
- Pacific Far East Line, Inc. v. United StatesUnited States Court of Claims · 1976
- United States v. ShepardDistrict Court, N.D. New York · 1961
- Ramirez v. United StatesUnited States Court of Claims · 1976
2 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Ripley v. CommissionerUnited States Tax Court · 1995
- Joseph Pesko and Stephanie Pesko v. The United StatesCourt of Appeals for the Federal Circuit · 1990
- Ripley v. CommissionerUnited States Tax Court · 1995
- Walter R. Ripley, Donee-Transferee of Mildred M. Ripley, Donor, and Melynda H. Ripley, Donee-Transferee of Mildred M. Ripley, Donor v. CommissionerUnited States Tax Court · 1995