United States Eighth Circuit

The IRS may examine and assess deficiencies resulting from errors in carriedback net operating loss cases even after the Tax Court has issued a final decision for the carryback year.

Appellate Information

• Decided 03/06/2006
• Published 03/06/2006

Judges

• MURPHY, Circuit Judge., Before MURPHY, FAGG, and SMITH, Circuit Judges.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Gilbert Rothenberg, argued, Tax Division, U.S. Dept. of Justice, Washington, DC (Richard Farber and Francesca U. Tamami, on the brief), for appellant.


• For Appellees:
  
• Thomas V.M. Linguanti, argued, Chicago, IL (Gregg D. Lemein, Robert S. Walton and Gregory S. Lyman, on the brief), for appellee.