Legal Opinion
Louis E. Roszkos and Vivian L. Roszkos v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided June 20, 1988No. 87-7316PublishedCited by 29 opinions
1Opinion of the Court
BRUNETTI, Circuit Judge:
BACKGROUND
Louis and Vivian Roszkos (“the Rosz-kos”) filed joint federal tax returns for the years 1973 through 1976, reflecting losses incurred and investment credits for various partnerships in which they participated. The Internal Revenue Service (“IRS”) initiated an investigation of those returns. In connection with that investigation, the Roszkos executed periodic Forms 872, consenting to a limited extension of the ordinary three-year statute of limitations for assessment of tax deficiencies. See IRC § 6501(a). Eventually, in late 1981, the Roszkos executed Forms…
2Cases cited6 opinions
- Miller v. Safeco Title Insurance Co.Court of Appeals for the Ninth Circuit · 1985
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Pursell v. CommissionerUnited States Tax Court · 1962
- Susan J. Mayors v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Richard L. Mulvania v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
1 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Conrad Keado v. United States of America, Conrad L. Keado and Linda W. Keado v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Candyce Martin 1999 Irrevocable Trust v. United StatesCourt of Appeals for the Ninth Circuit · 2014
- Gerald D. Ward and Joan Ward (Deceased) v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Thoburn v. CommissionerUnited States Tax Court · 1990
- Harry Holof and Norma Holof v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1989
24 more not listed; retrieve them via the Exa API.