Ramon Portillo and Dolores Portillo v. Commissioner of Internal Revenue

U.S. Court of Appeals, Fifth Circuit · Decided 1991-06-11

Cited by 190 later decision(s) in our corpus · see the citation network in Lexace

From the opinion

GOLDBERG, Circuit Judge: Ramon Portillo appeals from the Tax Court’s rejection of his challenge to a notice of deficiency from the Internal Revenue Service (the “I.R.S.”). Portillo initially argues that the simple computerized matching of Portillo’s employer's Form 1099 with Portillo’s Form 1040 was not a “determination” as required by section 6212(a) of the Internal Revenue C…

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