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United States Tenth Circuit


SMITH v. COMM'R OF INTERNAL REVENUE, 00-9032

Omission of the petition date from a notice of deficiency does not render the notice invalid, and is therefore sufficient to toll the limitations period for the assessment of tax deficiencies under IRC 6503(a)(1).

Appellate Information

  • Decided 12/21/2001
  • Published 12/21/2001

Judges

  • TACHA, Chief Circuit Judge., Before TACHA, Chief Judge, GARTH, and EBEL, Circuit Judges.

Court

  • United States Tenth Circuit

Counsel

  • For Appellant:
  • Charles S. Parnell (William R. Lambert, with him on the briefs), Lakewood, CO, appearing for Appellant.

  • For Appellees:
  • Patricia M. Bowman, (David I. Pincus, with her on the brief), Attorneys, Tax Division, Department of Justice, Washington, DC, appearing for Appellee.
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