Matter of Dorney v. Jayco, Inc.

How courts have described this case

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

• premising application of doctrine on intent to comply with applicable provision
• stat- ing that the Commissioner’s failure to adhere to the 120-day timeframe means that the NBAP is untimely but does not invalidate either notice
• events occurring during the examination are not determinative as to whether TEFRA applies
• the Commissioner issued an FPAA followed by a notice of deficiency

Source: CourtListener parenthetical corpus (CC0).