United States v. Martinez (In Re Martinez)
Court of Appeals for the Fifth Circuit
1Opinion of the Court
REAVLEY, Circuit Judge:
This appeal presents questions of a limitation bar to income tax adjustments for limited partnerships and the effectiveness of extensions executed by the tax matters partner. Debtor Elvin L. Martinez seeks to avoid tax liabilities associated with various partnerships for the years 1987 through 1993, which he contends were discharged in his personal bankruptcy because the Internal Revenue Service (IRS) failed to assess the taxes within the three-year limitations period for doing so. The issue on appeal is whether the limitations period was tolled by actions of the tax…
2Cases cited13 opinions
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- Computer Programs Lambda, Ltd. v. CommissionerUnited States Tax Court · 1987
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- American Equitable Assur. Co. of New York v. HelveringCourt of Appeals for the Second Circuit · 1933
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