Legal Opinion
Donald Feldman and Patricia Feldman, A/K/A Patsy Jane Feldman v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided May 17, 1994No. 93-4519PublishedCited by 67 opinions
1Opinion of the Court
DUBINA, Circuit Judge:
This appeal concerns a notice of deficiency disallowing deductions arising out of appellants’ (“the Feldmans”) investments in three tax shelter limited partnerships. The Feld-mans, husband and wife, do not contest the merits of these deficiencies and penalties, but argue that they are barred by the statute of limitations and that Patricia Feldman should receive innocent spouse relief under 26 U.S.C. § 6013(e). 1 The Tax Court found the Feldmans’ contentions to be without merit. Because we agree with the Tax Court’s findings, we affirm the judgment.
I. STATEMENT OF THE…
2Cases cited27 opinions
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- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
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3Cited by67 opinions
- Tefel v. RenoCourt of Appeals for the Eleventh Circuit · 1999
- Thomas W. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2003
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- Leon S. Malachinski v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
- Philip Friedman, Anna Friedman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1995
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