United States Second Circuit

Although a Letter 987, which indicated that the IRS District Director had accepted a tax return examiner's Form 4549-CG report, may have been misleading, it did not constitute a closing agreement precluding the IRS from further modifying the plaintiffs' 1995 federal income tax return.

Appellate Information

• Decided 03/04/2003
• Published 03/04/2003

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.