Legal Opinion

Charles D. Beard, Jr. Mary Sue Beard v. United States of America, John G. Beard Louise H. Beard v. United States

Court of Appeals for the Eleventh Circuit

Decided June 11, 1993No. 92-6296PublishedCited by 16 opinions

1Opinion of the Court

KRAVITCH, Circuit Judge:

The Subchapter S Revision Act of 1982 (SSRA), Pub.L. 97-354, 96 Stat. 1669 (currently codified at 26 U.S.C. §§ 6241-45 (1988)), generally requires shareholders in S corporations to follow the same procedures which partners in partnerships must follow to contest adjustments made by the Internal Revenue Service (IRS) to their business entity’s tax return. 26 U.S.C. § 6244. The sole question in this case is whether Congress exempted from those procedures S corporations having ten or fewer shareholders, just as it exempted partnerships with ten or fewer partners. See id. §…

2Cases cited10 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. United States v. CartwrightSupreme Court of the United States · 1973
  4. Dixon v. United StatesSupreme Court of the United States · 1965
  5. Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985

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3Cited by16 opinions

  1. Tarrant v. Department of TaxesSupreme Court of Vermont · 1999
  2. Twenty-Three Nineteen Creekside, Inc. Michael E. Baldigo v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1995
  3. Valentino v. Franchise Tax BoardCalifornia Court of Appeal · 2001
  4. Heller v. Franchise Tax BoardCalifornia Court of Appeal · 1994
  5. Home of Faith v. CommissionerCourt of Appeals for the Tenth Circuit · 1994

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