TAYLOR v. C.I.R.

No. 85-3063 Non-Argument Calendar.

771 F.2d 478 (1985)

Billy D. TAYLOR, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

September 17, 1985.


Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Gilbert S. Rothenberg, Steven I. Frahm, U.S. Dept. of Justice, Tax Div., Washington, D.C., for appellee.

Before TJOFLAT, VANCE and KRAVITCH, Circuit Judges.


PER CURIAM:

Appellant taxpayer contends that the United States Tax Court improperly dismissed his petition for failure to state a claim upon which relief can be granted. The Tax Court ruled that the petition did not comply with Tax Court Rule 34(b)(5), 26 U.S.C. foll. § 7453, which requires that the petition set forth "clear and concise lettered statements of facts," and that it was therefore impossible to discern whether the petition stated a claim. We hold...

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