HEFTI v. C.I.R.

No. 89-1302.

899 F.2d 709 (1990)

Charles and Marion HEFTI, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided March 26, 1990.


Attorney(s) appearing for the Case

James J. Knappenberger, Clayton, Mo., for appellants.

Janet Bradley, Washington, D.C., for appellee.

Before FAGG, Circuit Judge, FLOYD R. GIBSON, and BRIGHT, Senior Circuit Judges.


FLOYD R. GIBSON, Senior Circuit Judge.

Charles and Marion Hefti appeal the tax court's1 dismissal of their case for failure to comply with orders of that court. We vacate the judgment and remand for determination of whether Treas. Reg. § 301-7609-5(b) exceeds the congressional authorization in I.R.C. § 7609(e).

I. BACKGROUND

A. The Dismissal

The Heftis received a statutory notice of deficiency from...

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