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BEARD v. U.S.

No. 92-6296.

992 F.2d 1516 (1993)

Charles D. BEARD, Jr.; Mary Sue Beard, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. John G. BEARD; Louise H. Beard, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

June 11, 1993.

Attorney(s) appearing for the Case

Jack W. Selden, U.S. Atty., Caryl P. Privett, Birmingham, AL, Gary R. Allen, Tax Div., Dept. of Justice, Janet Kay Jones, Brian C. Griffin, Richard Farber, Steven Parks, Washington, DC, for defendant-appellee.

Before FAY and KRAVITCH, Circuit Judges, and RONEY, Senior Circuit Judge.

KRAVITCH, Circuit Judge:

The Subchapter S Revision Act of 1982 (SSRA), Pub.L. 97-354, 96 Stat. 1669 (currently codified at 26 U.S.C. §§ 6241-45 (1988)), generally requires shareholders in S corporations to follow the same procedures which partners in partnerships must follow to contest adjustments made by the Internal Revenue Service (IRS) to their business entity's tax return. 26 U.S.C. § 6244. The sole question in this case is whether Congress exempted...

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