BENZVI v. C.I.R.

No. 85-8734.

787 F.2d 1541 (1986)

Jeremiah BENZVI and Robert L. McLeroy, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

April 29, 1986.


Attorney(s) appearing for the Case

Martin A. Schainbaum, Kathleen A. Miller, San Francisco, Cal., for petitioners-appellants.

Michael L. Paup, Washington, D.C., Glenn L. Archer, Roger M. Olsen, Richard Farber, Gary D. Gray, Asst. Attys. Gen., Washington, D.C., for respondent-appellee.

Before TJOFLAT, and KRAVITCH, Circuit Judges, and DUMBAULD, Senior District Judge.


KRAVITCH, Circuit Judge:

This appeal requires us to decide whether a letter sent by the IRS is a deficiency determination and notice sufficient to trigger the jurisdiction of the United States Tax Court within the meaning of I.R.C. §§ 6212(a) and 6213(a).1

Appellants Benzvi and McLeroy are two of 111 taxpayers who filed suit in the Tax Court of the United States in response...

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