United States Second Circuit

While a Letter 987 may have been misleading, it did not constitute a closing agreement precluding the IRS from further modifying taxpayers' 1995 federal income tax return, and a sufficient determination of a deficiency was made.

Appellate Information

• Decided 02/28/2003
• Published 03/03/2003

Judges

• VAN GRAAFEILAND, Senior Circuit Judge., Before:  VAN GRAAFEILAND, CARDAMONE and JACOBS, Circuit Judges.

Court

• United States Second Circuit

Counsel

• For Appellant:
  
• Jay J. Freireich,Esq., Poe & Freireich, P.A., Florham Park, NJ, for Appellants.


• For Appellees:
  
• Eileen J. O'Connor, Esq., Bruce R. Ellisen, Esq., Carol Ann Barthel, Esq., U.S. Department of Justice, Washington, DC, for Appellees.