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.