Legal Opinion
Sylvia A. Sliwa v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided February 12, 1988No. 86-7430PublishedCited by 54 opinions
1Opinion of the Court
POOLE, Circuit Judge:
This case arises out of alleged deficiencies in the 1976, 1976, and 1977 federal income tax paid by appellant Sylvia Sliwa. After Ms. Sliwa filed a petition in the tax court seeking a re-determination of the deficiencies set forth by the Commissioner, the Commissioner of Internal Revenue conceded that Sliwa’s return was not in fact deficient, and stipulated to the dismissal of the Notice of Deficiency against her.
Sliwa then applied to the Tax Court for an award of attorney’s fees under section 7430 of the Internal Revenue Code, 26 U.S. C. § 7430. Under the statute, a…
2Cases cited19 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Branerton Corp. v. CommissionerUnited States Tax Court · 1974
- Adams v. CommissionerUnited States Tax Court · 1973
14 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
- Clair S. Huffman v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 1992
- Leopold Z. Sher and Karen B. Sher v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Sokol v. CommissionerUnited States Tax Court · 1989
- Estate of William Davidson Merchant, Iii, Deceased, Margaret Norling Merchant, Administrator v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1991
- John W. Bode and Toni Bode v. United States of America, Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1991
49 more not listed; retrieve them via the Exa API.