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KAPPEL'S ESTATE v. C. I. R.

No. 78-2148.

615 F.2d 91 (1980)

ESTATE of William J. KAPPEL (Deceased), (William D. Kappel and Sara Kappel Courtley, Co-Executors) and Sara Kappel Courtley, Surviving Wife, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Third Circuit.

Decided February 4, 1980.

Attorney(s) appearing for the Case

Robert G. MacAlister, John A. Metz (argued), Pittsburgh, Pa., for appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Gary R. Allen, Francis J. Gould (argued), Attys., Tax Division, Dept. of Justice, Washington, D. C., for appellees.

Before GIBBONS and HIGGINBOTHAM, Circuit Judges, and ZIEGLER, District Judge.

OPINION OF THE COURT

GIBBONS, Circuit Judge.

This appeal by taxpayers from a decision of the Tax Court requires consideration of the interrelationship between the limitation on assessment and collection of tax in 26 U.S.C. § 6501 (1976) and the mitigation and adjustment provisions of the Internal Revenue Code, 26 U.S.C. §§ 1311-1314 (1976), dealing with maintenance of inconsistent positions. Specifically, we must determine whether, when a...

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