United States First Circuit
CC&F W. OPERATIONS LTD. P'SHIP v. COMM'R OF INTERNAL REVENUE, 01-1169
The three-year extension for the IRS to file a tax-assessment under 26 USC 6229(c)(2) (1994) applies even where taxpayer's gross income was adequately disclosed on its return and attached schedules.
Appellate Information
- Decided 12/10/2001
- Published 12/10/2001
Judges
- BOUDIN, Chief Judge., Before Boudin, Chief Judge, Stahl, Senior Circuit Judge, and Lynch, Circuit Judge.
Court
- United States First Circuit
Counsel
- For Appellant:
- William F. Nelson, with whom J. Bradford Anwyll, Christopher P. La Puma, Nathan E. Clukey, McKee Nelson, Ernst & Young LLP, Peter J. Genz and King & Spalding were on brief for petitioner.
- For Appellees:
- Charles Bricken, Tax Division, Department of Justice, with whom Claire Fallon, Acting Assistant Attorney General, and Bruce R. Ellisen, Tax Division, Department of Justice, were on brief for respondent.