Legal Opinion
Smith v. Commissioner
Court of Appeals for the Tenth Circuit
Decided December 21, 2001No. 00-9032PublishedCited by 21 opinions
1Opinion of the Court
TACHA, Chief Circuit Judge.
In March 1999, appellants Eric E. Smith and Dorothy M. Smith received a notice of deficiency for their 1995 taxes. The Smiths filed a petition for reconsideration with the United States Tax Court in June 1999, arguing that the notice was invalid and therefore failed to toll the statute of limitations. The Tax Court held that the notice was valid and tolled the statute of limitations. The taxpayers appealed. We exercise jurisdiction pursuant to I.R.C. § 7482(a)(1) and affirm.
I. Background
The Smiths timely filed their 1995 tax return. The limitations period for the…
2Cases cited4 opinions
- United States National Bank v. Independent Insurance Agents of America, Inc.Supreme Court of the United States · 1993
- Duke Energy Natural Gas Corp. v. CommissionerCourt of Appeals for the Tenth Circuit · 1999
- William B. Scheidt and Wanda C. Scheidt v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
- ROCHELLE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
3Cited by21 opinions
- Virgil B. Elings v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2003
- McGee v. Comm'rUnited States Tax Court · 2004
- Qinetiq US Holdings, Inc. & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 2017
- John C. Hom & Associates, Inc. v. CommissionerUnited States Tax Court · 2013
- Nu-Look Design, Inc. v. Comm'rUnited States Tax Court · 2003
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