Legal Opinion
Billy D. Taylor v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided September 17, 1985No. 85-3063PublishedCited by 14 opinions
Non-Argument Calendar.
1Per curiam
Appellant taxpayer contends that the United States Tax Court improperly dismissed his petition for failure to state a claim upon which relief can be granted. The Tax Court ruled that the petition did not comply with Tax Court Rule 34(b)(5), 26 U.S.C. foil. § 7453, which requires that the petition set forth “clear and concise lettered statements of facts,” and that it was therefore impossible to discern whether the petition stated a claim. We hold that where a petition fails to set forth facts as required by Tax Court Rule 34(b)(5), the Tax Court is correct in dismissing the petition for…
2Cases cited4 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Welch v. HelveringSupreme Court of the United States · 1933
- Lavern Scherping v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1984
- Oren F. Potito, Oren F. Potito and Helen M. Potito v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
3Cited by14 opinions
- Norman D. Carter and Cecilia P. Carter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Eric A. Pollard v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1986
- Joseph A. Lefebvre v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1987
- Eric A. Pollard v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1987
- Gene and Debra Webb v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1989
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