Legal Opinion
Coffey v. Commissioner
Court of Appeals for the Eighth Circuit
Decided December 2, 2011No. 11-1362PublishedCited by 7 opinions
1Opinion of the Court
BENTON, Circuit Judge.
In 2009, Judith S. Coffey received a notice of deficiency from the Internal Revenue Service. She contested the assessments, asserting the time bar in 26 U.S.C. § 6501(a). Claiming an interest in this issue, the government of the United States Virgin Islands (USVI) sought to intervene, either as of right under Civil Rule 24(a)(2), or permissively under Civil Rule 24(b)(2). The tax court denied intervention. The USVI appeals. Having jurisdiction under 26 U.S.C. § 7482(a)(1), this court reverses and remands.
Although a U.S. territory, the USVI is a separate taxing entity. In…
2Cases cited8 opinions
- William E. Nuesse, Commissioner of Banks, State of Wisconsin v. William Camp, Comptroller of the CurrencyCourt of Appeals for the D.C. Circuit · 1967
- United States v. Pitney Bowes, Inc., Edo Corporation Plessey, Inc. Vernitron Corp., Baii Banking Corp., Movant-AppellantCourt of Appeals for the Second Circuit · 1994
- Mausolf v. BabbittCourt of Appeals for the Eighth Circuit · 1996
- McCabe v. ParkerCourt of Appeals for the Eighth Circuit · 2010
- South Dakota Ex Rel. Barnett v. United States Department of InteriorCourt of Appeals for the Eighth Circuit · 2003
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- McHenry v. CommissionerCourt of Appeals for the Fourth Circuit · 2012
- Government of the United States Virgin Islands v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2014
- Bartholomew v. District of Columbia Office of Tax & RevenueDistrict of Columbia Court of Appeals · 2013
- Judith Coffey v. CIRCourt of Appeals for the Eighth Circuit · 2021
- McHenry v. CommissionerCourt of Appeals for the Fourth Circuit · 2012
2 more not listed; retrieve them via the Exa API.