Legal Opinion
Powers v. Commissioner
Court of Appeals for the Fifth Circuit
Decided January 26, 1995No. 94-40005, 94-40006 and 94-40007PublishedCited by 18 opinions
1Opinion of the Court
STEWART, Circuit Judge:
This consolidated appeal from the Tax Court involves the issue of the sufficiency of an award for litigation costs to prevailing taxpayer M. Lane Powers under § 7430 of the Internal Revenue Code as well as the issue of whether Powers made an unequivocal, irrevocable election to relinquish the three-year carryback provision of § 172(b) of the Code. We affirm in part, reverse in part, and remand in part.
Assignments of Error
On appeal, M. Lane Powers alleges the following assignments of error:(1) That the Tax Court erred in holding that he unequivocally elected for the…
2Cases cited14 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Lavespere v. Niagara Machine & Tool Works, Inc.Court of Appeals for the Fifth Circuit · 1990
- Zulema De La Garza Perales, Cross-Appellants v. Richard Casillas, Cross-AppelleesCourt of Appeals for the Fifth Circuit · 1992
- John W. Bode and Toni Bode v. United States of America, Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1991
- David E. Heasley and Kathleen Heasley, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Fifth Circuit · 1992
9 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Estate of Cervin v. CommissionerCourt of Appeals for the Fifth Circuit · 2000
- Cozean v. CommissionerUnited States Tax Court · 1997
- Ragan v. CommissionerCourt of Appeals for the Fifth Circuit · 2000
- Moulton v. United States (In Re Moulton)United States Bankruptcy Court, M.D. Florida · 1996
- Powers v. C.I.R.Court of Appeals for the Fifth Circuit · 1995
13 more not listed; retrieve them via the Exa API.