Legal Opinion
Patrick James Ryan v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided June 2, 1982No. 81-2459, 81-2460PublishedCited by 16 opinions
1Opinion of the Court
OPINION OF THE COURT
GIBBONS, Circuit Judge:
Appellant Patrick James Ryan is an individual taxpayer who has filed his federal income tax returns based on a calendar year. On March 1, 1977, the Commissioner of Internal Revenue (hereinafter Commissioner) invoked 26 U.S.C. § 6851(a) which authorizes, under certain circumstances, a termination of an individual’s taxable year. On April 11,1977, the Commissioner made a termination assessment of $81,107.64 against Ryan for the period between January 1, 1977 and March 1, 1977.
On April 11, 1978, Ryan applied for an automatic extension of time until June…
2Cases cited11 opinions
- Parr v. United StatesSupreme Court of the United States · 1956
- Electrical Fittings Corp. v. ThomasSupreme Court of the United States · 1939
- W. W. Windle Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1977
- Morgenstern Chemical Co., Inc. v. Schering CorporationCourt of Appeals for the Third Circuit · 1950
- United States v. California Eastern Line, Inc.Supreme Court of the United States · 1955
6 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Chai v. CommissionerCourt of Appeals for the Second Circuit · 2017
- Clapp v. CommissionerCourt of Appeals for the Ninth Circuit · 1989
- H.R. Technologies, Inc. v. Astechnologies, Inc.Court of Appeals for the Federal Circuit · 2002
- Tristani Ex Rel. Karnes v. RichmanCourt of Appeals for the Third Circuit · 2011
- Inverworld, Ltd. v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1992
11 more not listed; retrieve them via the Exa API.