Daniel M. Kelley Nancey N. Kelley v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that we review for abuse of discretion the tax court’s denial of leave to amend
• rejecting adjustment to individual shareholder’s return based on disallowance of corporate deductions.
• Section 6501 “does not indicate whether the relevant return is the taxpayer’s or the corporation’s.”
• “While [the Senate Report] refers to an unqualified corporation as an example, it leaves open whether the statute of limitations applies in other situations.”
• Section 6501 \does not indicate whether the relevant return is the taxpayer's or the corporation's.\
• Section 6501 \does not indicate whether the relevant return is the taxpayer's or the corporation's.\

Source: CourtListener parenthetical corpus (CC0).