Miles Production Co. v. C.I.R., No. 92-4284

CourtUnited States Courts of Appeals. United States Court of Appeals (5th Circuit)
Writing for the CourtBefore GOLDBERG, JOLLY, and WIENER; GOLDBERG
Citation987 F.2d 273
Parties-2219, 93-1 USTC P 50,189 MILES PRODUCTION COMPANY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Docket NumberNo. 92-4284
Decision Date01 April 1993
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5 practice notes
  • Dees v. Comm'r, 148 T.C. No. 1
    • United States
    • United States Tax Court
    • February 2, 2017
    ...that the Commissioner determined a deficiency. This approach is evident in Miles Prod. Co. v. Commissioner, 96 T.C. 595 (1991), aff'd, 987 F.2d 273 (5th Cir. 1993), a case in which the Commissioner issued a notice of deficiency determining deficiencies in the taxpayer's windfall profits tax......
  • Polsky v. Werfel, CIVIL ACTION No. 14-655
    • United States
    • United States District Courts. 3th Circuit. United States District Court (Eastern District of Pennsylvania)
    • February 23, 2015
    ...a Notice of Deficiency.26 26 U.S.C. §§ 6211(a), 6212(a), 6213(b)(2)(A); Treas. Reg. § 301.6211-1(a); Miles Production Co. v. C.I.R., 987 F.2d 273, 277 (5th Cir. 1993) (citation omitted). A Notice of Deficiency is the taxpayer's "ticket to the Tax Court" to litigate the merits of the deficie......
  • Polsky v. Werfel, Civil Action No. 14–655.
    • United States
    • United States District Courts. 3th Circuit. United States District Court (Eastern District of Pennsylvania)
    • February 23, 2015
    ...a Notice of Deficiency.26 26 U.S.C. §§ 6211(a), 6212(a), 6213(b)(2)(A) ; Treas. Reg. § 301.6211–1(a) ; Miles Production Co. v. C.I.R., 987 F.2d 273, 277 (5th Cir.1993) (citation omitted). A Notice of Deficiency is the taxpayer's “ticket to the Tax Court” to litigate the merits of the defici......
  • U.S. v. Bishop, No. 00-20282
    • United States
    • United States Courts of Appeals. United States Court of Appeals (5th Circuit)
    • August 29, 2001
    ...decrease it according to the formula above, as the taxpayer returns the credit now known to be unwarranted. See Miles Prod. Co. v. CIR, 987 F.2d 273, 276-77 & n.3 (5th Cir. 1993); United States v. Wilkes, 946 F.2d 1143, 1149 (5th Cir. 1991). 9. Locus testified that he was suspicious of a ne......
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5 cases
  • Dees v. Comm'r, 148 T.C. No. 1
    • United States
    • United States Tax Court
    • February 2, 2017
    ...that the Commissioner determined a deficiency. This approach is evident in Miles Prod. Co. v. Commissioner, 96 T.C. 595 (1991), aff'd, 987 F.2d 273 (5th Cir. 1993), a case in which the Commissioner issued a notice of deficiency determining deficiencies in the taxpayer's windfall profits tax......
  • Polsky v. Werfel, CIVIL ACTION No. 14-655
    • United States
    • United States District Courts. 3th Circuit. United States District Court (Eastern District of Pennsylvania)
    • February 23, 2015
    ...a Notice of Deficiency.26 26 U.S.C. §§ 6211(a), 6212(a), 6213(b)(2)(A); Treas. Reg. § 301.6211-1(a); Miles Production Co. v. C.I.R., 987 F.2d 273, 277 (5th Cir. 1993) (citation omitted). A Notice of Deficiency is the taxpayer's "ticket to the Tax Court" to litigate the merits of the deficie......
  • Polsky v. Werfel, Civil Action No. 14–655.
    • United States
    • United States District Courts. 3th Circuit. United States District Court (Eastern District of Pennsylvania)
    • February 23, 2015
    ...a Notice of Deficiency.26 26 U.S.C. §§ 6211(a), 6212(a), 6213(b)(2)(A) ; Treas. Reg. § 301.6211–1(a) ; Miles Production Co. v. C.I.R., 987 F.2d 273, 277 (5th Cir.1993) (citation omitted). A Notice of Deficiency is the taxpayer's “ticket to the Tax Court” to litigate the merits of the defici......
  • U.S. v. Bishop, No. 00-20282
    • United States
    • United States Courts of Appeals. United States Court of Appeals (5th Circuit)
    • August 29, 2001
    ...decrease it according to the formula above, as the taxpayer returns the credit now known to be unwarranted. See Miles Prod. Co. v. CIR, 987 F.2d 273, 276-77 & n.3 (5th Cir. 1993); United States v. Wilkes, 946 F.2d 1143, 1149 (5th Cir. 1991). 9. Locus testified that he was suspicious of a ne......
  • Request a trial to view additional results

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