Legal Opinion
R.A. Gaska Terry L. Lesley and Everett F. Telljohnann v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided September 11, 1986No. 85-1744PublishedCited by 11 opinions
1Opinion of the Court
NATHANIEL R. JONES, Circuit Judge.
This appeal is one of a number brought in several circuits concerning the tax court’s characterization of a certain pre-fil-ing notification letter issued by the IRS. The question is whether the tax court correctly dismissed plaintiffs’ petition for lack of jurisdiction on the basis that a pre-filing notification letter is not the equivalent of a notice of deficiency. We affirm the order of the tax court dismissing the petition.
The IRS sent plaintiffs the following pre-filing notification form letter:
Tax Shelter Promotion:
*See below
Tax Year: 1983
*Liberty…
2Cases cited6 opinions
- Commissioner of Internal Revenue v. StewartCourt of Appeals for the Sixth Circuit · 1951
- Jeremiah Benzvi and Robert L. McLeroy v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
- Corbett v. FrankCourt of Appeals for the Ninth Circuit · 1961
- Steven E. Donley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
- W.M. Spector and James M. Stokes v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1986
1 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Richard L. Abrams v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Andrew Crispo Gallery, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Kellogg v. CommissionerUnited States Tax Court · 1987
- Hubbard v. CommissionerUnited States Tax Court · 1987
- Barnes v. Comm'rUnited States Tax Court · 2008
6 more not listed; retrieve them via the Exa API.