Legal Opinion
Jeremiah Benzvi and Robert L. McLeroy v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided April 29, 1986No. 85-8734PublishedCited by 54 opinions
1Opinion of the Court
KRAVITCH, Circuit Judge:
This appeal requires us to decide whether a letter sent by the IRS is a deficiency determination and notice sufficient to trigger the jurisdiction of the United States Tax Court within the meaning of I.R.C. §§ 6212(a) and 6213(a). 1
Appellants Benzvi and McLeroy are two of 111 taxpayers who filed suit in the Tax Court of the United States in response to a pre-filing notification (PFN) letter from the IRS. The Tax Court dismissed their petition because the taxpayers had not received notices of a deficiency determination; thus the Tax Court concluded it lacked…
2Cases cited8 opinions
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Commissioner v. ShapiroSupreme Court of the United States · 1976
- Foster v. Comm'rUnited States Tax Court · 1983
- Scar v. CommissionerUnited States Tax Court · 1983
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
3 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Ramon Portillo and Dolores Portillo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- Powers v. CommissionerUnited States Tax Court · 1993
- United States v. VerdunnCourt of Appeals for the Eleventh Circuit · 1996
- Richard D. Bokum, Ii, Margaret B. Bokum v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
49 more not listed; retrieve them via the Exa API.