1. Home
  2. Browse Decisions
  3. F.3d
  4. 987 F.3d
  5. 987 F.3d 808 (2021)
 

COFFEY v. C.I.R.

Nos. 18-3256, 18-3259.

987 F.3d 808 (2021)

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: February 12, 2021.

Attorney(s) appearing for the Case

Counsel who originally argued for the appellant was Judith Hagley , USDOJ, Tax Division, Appellate Section, Washington, DC. Appearing on appellant's brief were Gilbert Steven Rothenberg , Francesca Ugolini , and Richard Caldarone , all of the USDOJ, Tax Division, Appellate Section, Washington, DC.

Counsel who originally argued for the Coffey appellees was Randall P. Andreozzi , of Clarence, NY. Appearing on the Coffey brief were Heather L. Marello and Michael J. Tedesco of Clarence, NY.

Counsel who originally argued for appellee Government of U.S. Virgin Islands was Geoffrey P. Eaton of Washington, DC. Also appearing of USVI brief was Carol Jacobs of St. Thomas , U.S. Virgin Islands.

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...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases