Legal Opinion
Barry I. Fredericks v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided September 11, 1997No. 96-7748PublishedCited by 33 opinions
1Opinion of the Court
OPINION OF THE COURT
ALDISERT, Circuit Judge.
We must decide whether this is an appropriate case to apply the doctrine of estoppel against the Internal Revenue Service (IRS). Barry I. Fredericks appeals a decision of the United States Tax Court that approved a deficiency assessed by the Commissioner of Internal Revenue in July 1992 for Fredericks’ 1977 income tax return. The IRS action requires the taxpayer to pay an additional tax of $28,361 and approximately $158,000 in interest on the basis of a disallowed tax-shelter deduction. The taxpayer filed a timely 1977 tax return, but the IRS took…
2Cases cited45 opinions
- Federal Crop Ins. Corp. v. MerrillSupreme Court of the United States · 1947
- Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
- Office of Personnel Management v. RichmondSupreme Court of the United States · 1990
- Schweiker v. HansenSupreme Court of the United States · 1981
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
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3Cited by33 opinions
- Messa v. Omaha Property & Casualty InsuranceDistrict Court, D. New Jersey · 2000
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Tefel v. RenoCourt of Appeals for the Eleventh Circuit · 1999
- Jonathan B. Geftman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1998
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
28 more not listed; retrieve them via the Exa API.