David H. Hillman Suzanne Hillman v. Internal Revenue Service
Court of Appeals for the Fourth Circuit
1Opinion of the Court
Reversed and remanded by published opinion. Senior Judge HAMILTON wrote Parts I and II of the opinion, in which Judge WILKINS and Judge WILLIAMS joined. Judge WILLIAMS wrote Part III of the opinion, in which Judge WILKINS joined. Senior Judge HAMILTON wrote a dissenting opinion with respect to Part III.
OPINION
HAMILTON, Senior Circuit Judge:
I
In mid-July 1997, David and Suzanne Hillman (the Hillmans) received written notice from the Commissioner of the United States Internal Revenue Service (the Commissioner) that a deficiency existed in the amount of federal income taxes they had paid for…
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