Legal Opinion
St. Joseph Lease Capital Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided December 20, 2000No. 99-2473PublishedCited by 6 opinions
1Opinion of the Court
Affirmed by published opinion. Judge NIEMEYER wrote the opinion, in which Judge MICHAEL and Chief Judge STAMP joined.
OPINION
NIEMEYER, Circuit Judge:
We are presented with the question under the Tax Code of whether the mailing by the Internal Revenue Service (“IRS”) of a misaddressed notice of income tax deficiency suspended' — under 26 U.S.C. § 6503(a) — the running of the three-year limitations period within which the IRS must assess taxes due. For the reasons that follow, we affirm the United States Tax Court’s decision that this period of limitations was suspended by the mailing, when the…
2Cases cited12 opinions
- Frieling v. CommissionerUnited States Tax Court · 1983
- Lifter v. CommissionerUnited States Tax Court · 1973
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- William I. Tenzer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Henry G. Pugsley v. Commissioner of Internal Revenue, Joseph T. Rezzonico v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
7 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Allnutt v. Commissioner, IRSCourt of Appeals for the Fourth Circuit · 2008
- David S. v. United StatesUnited States Court of Federal Claims · 2007
- Downing v. Comm'rUnited States Tax Court · 2007
- Colvin v. Comm'rUnited States Tax Court · 2007
- Marcy v. Comm'rUnited States Tax Court · 2008
1 more not listed; retrieve them via the Exa API.