Donald Feldman and Patricia Feldman, A/K/A Patsy Jane Feldman 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.

• “When a taxpayer raises the affirmative defense of the statute of limitations, the taxpayer bears the burden to prove that defense.”
• the Commissioner's determination of a deficiency is ordinarily presumed correct, and the taxpayer has the burden of proving it is erroneous or arbitrary
• “the failure to present a sufficient record can itself serve 21 a basis for summary affirmance”
• taxpayers' estoppel argument against enforcement of their extension of the limitations period was rejected
• the test for whether an item is attributable to a spouse is whether the spouse has sufficient connection through ownership rights or otherwise to make it an item for which both spouses should bear responsibility

Source: CourtListener parenthetical corpus (CC0).