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MATTER OF QUEZADA

No. 19-51000.

982 F.3d 931 (2020)

In the MATTER OF: James QUEZADA and Simona Quezada, Debtors, James Quezada; Simona Quezada, Appellants, v. Internal Revenue Service, Appellee.

United States Court of Appeals, Fifth Circuit.

Filed December 11, 2020.

Attorney(s) appearing for the Case

Michael L. Cook , Attorney, Cook Brooks Johnson, P.L.L.C., Austin, TX, Carlos Quezada , Spring, TX, for Appellants.

Norah Bringer , Bruce Raleigh Ellisen , U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, Thomas M. Herrin , U.S. Department of Justice, Tax Division, Dallas, TX, for Appellee.

Before Jolly, Jones, and Willett, Circuit Judges.

This appeal presents a question of the limitations period for an assessment of tax liability, which in turn depends on the definition of the Internal Revenue Code term, "the return." The Internal Revenue Service assessed James Quezada in 2014 for tax deficiencies dating back...

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