United States Federal Circuit

In a tax dispute concerning the procedures to be followed when the IRS conducts a partnership proceeding under the Tax Equity and Fiscal Responsibility Act (TEFRA), I.R.C. sections 6221–6233, judgment of the trial court is affirmed where the IRS is under no obligation to issue notices of deficiency in circumstances where admissions in a settlement agreement form the basis for recomputation of taxes.

Appellate Information

• Decided 08/24/2011
• Published 08/24/2011

Judges

• PROST

Court

• United States Federal Circuit

Counsel