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STEWART v. C.I.R.

No. 19-3786.

999 F.3d 1150 (2021)

Jason STEWART; Kristy Stewart, Appellants v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: June 8, 2021.

Attorney(s) appearing for the Case

Eric Johnson , Johnson Tax Law, P.C., Saint Paul, MN, for Appellants.

Janet A. Bradley , Francesca Ugolini , U.S. Department of Justice, Tax Division, Appellate Section, Michael J. Desmond , U.S. Internal Revenue Service, Office of Chief Counsel, Washington, DC, for Appellee.

Before SHEPHERD, STRAS, and KOBES, Circuit Judges.

Are taxpayers entitled to a new hearing because a revenue officer included notes and correspondence about a meeting with their attorney in the official file that was later made available to the settlement officer who reviewed the case? The tax court1 said no, and we agree.

I.

Jason...

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