In Carlson v. Commissioner, 2015 U.S. App. LEXIS 9010 (9th Cir. 2015), here the panel affirmed a taxpayer appeal from the Tax Court. The Ninth Circuit opens with this line: "Karen Lee Carlson, appeals pro se from the Tax Court's decision, following a bench trial, concerning her income tax liability for tax years 2001 through 2004." In the next paragraph, the Court opens with this line: Contrary to Carlson's contention, the Tax Court correctly concluded that Carlson had received taxable income, such as compensation for work performed for private companies, while she resided in Oregon and Washington."
Then, in the third paragraph the Court opens with this line: "Moreover, the district court did not abuse its discretion by excluding Charles Allen Harman's proposed testimony regarding statutes and case law."
I know that appeals from the Tax Court to the Court Appeals are covered by Section 7482, here, which says: "The United States Courts of Appeals (other than the United States Court of Appeals for the Federal Circuit) shall have exclusive jurisdiction to review the decisions of the Tax Court * * * in the same manner and to the same extent as decisions of the district courts in civil actions tried without a jury; " But that does not make the Tax Court a district court.
Somebody was asleep at the word processor.
Jack Townsend offers this blog in conjunction with his Federal Tax Procedure Books, currently in the 2019 editions (Student and Practitioner). Annual editions of the books are published in August. Those books may be downloaded from SSRN (see the page link in the top right hand column of this blog). In addition, Jack uses this blog to discuss issues of federal tax procedure.
Showing posts with label Misc. Show all posts
Showing posts with label Misc. Show all posts
Sunday, May 31, 2015
Monday, November 19, 2012
Hardly Strictly Tax Procedure (11/19/12)
Mike Scarcella, In D.C. Circuit, Judge Calls Use of Acronyms 'Painful' (BLT Blog 11/19/12), here.
Jeffrey Toobin and Alan Dershowitz on the Supreme Court and the Obama Administration (92nd Street Y 11/16/12), here.
Christopher Schmidt, Justices Behaving Badly (Legal History Blog 11/19/12), here.
Daniel Altman, To Reduce Inequality, Tax Wealth, Not Income (NYT 11/18/12), here\.
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