Legal Opinion
W.M. Spector and James M. Stokes v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided May 7, 1986No. 85-2133PublishedCited by 22 opinions
1Per curiam
W.M. Spector and James Stokes appeal from an order of the United States Tax Court dismissing for lack of jurisdiction a consolidated petition for determination of purported deficiencies. We affirm.
On November 2, 1984, the Internal Revenue Service (IRS) sent appellants a letter notifying them of the IRS’ belief that any deductions or credits derived from investments in a tax shelter known as the “Liberty Financial 1983 Government Securities Trading Strategy” would not be allowable. The letter indicated that the IRS had not yet reviewed appellants’ tax returns to determine whether appellants…
2Cases cited3 opinions
- Laing v. United StatesSupreme Court of the United States · 1976
- Ignatius Page, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Abrams v. Commissioner Of Internal RevenueCourt of Appeals for the Fourth Circuit · 1986
3Cited by22 opinions
- Theresa E. Bartman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2006
- Richard L. Abrams v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Keller Tank Services II, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 2017
- Clovis I v. CommissionerUnited States Tax Court · 1987
- Kellogg v. CommissionerUnited States Tax Court · 1987
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