Legal Opinion
Deaton v. Commissioner
Court of Appeals for the Fifth Circuit
Decided February 9, 2006No. 05-60278, 05-60292PublishedCited by 9 opinions
1Opinion of the Court
DeMOSS, Circuit Judge:
Barbara and Ronny Deaton (the “Dea-tons”) appeal a decision of the United States Tax Court (the “Tax Court”) sustaining a finding of the Internal Revenue Service Appeals Office (the “Appeals Office”) that the Deatons’ 1994 remittance of $125,000 — which accompanied their Form 4868 application for an extension of time to file their 1993 tax return — was a “payment,” not a “deposit,” and that as such, it could not be credited against the Deatons’ 1994-1996 tax liabilities because it fell outside the “look-back period” of I.R.C. § 6511(b)(2)(A).
I. Facts and Proceedings
On…
2Cases cited21 opinions
- Harper v. Virginia Department of TaxationSupreme Court of the United States · 1993
- Cheek v. United StatesSupreme Court of the United States · 1991
- Rosenman v. United StatesSupreme Court of the United States · 1945
- Arthur C. Ewing A/K/A A. Clifford Ewing Maxine H. Ewing v. United StatesCourt of Appeals for the Fourth Circuit · 1990
- Dale K. And Donna L. Sandvall v. Commissioner Internal Revenue, Dale K. And Donna L. Sandvall v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
16 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Principal Life Insurance v. United StatesUnited States Court of Federal Claims · 2010
- Nicholas Acoustics & Specialty Co., Inc. v. United StatesDistrict Court, S.D. Mississippi · 2010
- Winford v. United StatesDistrict Court, W.D. Louisiana · 2012
- Ava Maureen Sawyer v. CommissionerUnited States Tax Court · 2014
- Ava Maureen Sawyer v. CommissionerUnited States Tax Court · 2014
4 more not listed; retrieve them via the Exa API.