Legal Opinion
William B. Scheidt and Wanda C. Scheidt v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided June 18, 1992No. 91-9008PublishedCited by 11 opinions
1Opinion of the Court
TACHA, Circuit Judge.
Appellants William and Wanda Scheidt appeal from an order of the United States Tax Court denying both their motion to dismiss for lack of jurisdiction and their motion for summary judgment. On appeal, appellants contend that the Commissioner’s misaddressed notice of deficiency to appellants failed to toll the three-year limitation period before which the Commissioner must assess tax deficiencies. We exercise jurisdiction under 26 U.S.C. § 7482(a) and affirm.
BACKGROUND
On June 15, 1979, appellants filed a joint federal income tax return for 1978. On June 9, 1982 — six days…
2Cases cited7 opinions
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Gregory W. McKay v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- Henry G. Pugsley v. Commissioner of Internal Revenue, Joseph T. Rezzonico v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Berger v. CommissionerCourt of Appeals for the Third Circuit · 1968
- Charles R. Sicker v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1987
2 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Smith v. CommissionerUnited States Tax Court · 2000
- Smith v. CommissionerCourt of Appeals for the Tenth Circuit · 2001
- Basdeo Balkissoon Gloria Balkissoon v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1993
- David S. v. United StatesUnited States Court of Federal Claims · 2007
- St. Joseph Lease Capital Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 2000
6 more not listed; retrieve them via the Exa API.