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COFFEY v. C.I.R.

Nos. 18-3256, 18-3259.

982 F.3d 1127 (2020)

Judith S. COFFEY, Appellee, Government of the United States Virgin Islands, ("V.I. Government"), Intervenor-Appellee v. COMMISSIONER OF INTERNAL REVENUE, Appellant. Estate of James Coffey, Judith Coffey Executrix, Appellee. v. Commissioner of Internal Revenue, Appellant.

United States Court of Appeals, Eighth Circuit.

Filed: December 15, 2020.

Attorney(s) appearing for the Case

Randall P. Andreozzi , Heather Lynn Marello , Michael J. Tedesco , Andreozzi & Bluestein, Clarence, NY, for Appellees.

Geoffrey P. Eaton , Winston & Strawn, Washington, DC, Vincent F. Frazer , Carol Thomas-Jacobs , Virgin Islands Department of Justice, Saint Thomas, VI, for Intervenor-Appellee.

Judith Ann Hagley , U.S. Department of Justice, Tax Division, William M. Paul , U.S. Internal Revenue Service, Office of Chief Counsel, Gilbert Steven Rothenberg , Senior Attorney, Francesca Ugolini , U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, for Appellant.

Before SMITH, Chief Judge, BENTON and KOBES, Circuit Judges.

The Commissioner of Internal Revenue determined that because Judith S. Coffey was not a bona fide resident of the United States Virgin Islands (USVI), she and James L. Coffey owed federal income tax for the 2003 and 2004 tax years. The Coffeys invoked the three-year statute of limitations in 26 U.S.C. § 6501(a). The USVI...

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