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whether the Estate of Lisle is liable for tax deficiencies
consistent with the instructions handed down by the Court of
Appeals for the Eleventh Circuit in Ballard v. Commissioner, 429
F.3d at 1027.
On June 16, 2005, this Court issued an order in the Kanter
deficiency cases directing that the Couvillion report be served
on the parties and be made a part of the record in those cases.
On December 16, 2005, this Court issued an order vacating
and setting aside the decisions entered in the Kanter deficiency
cases, striking the Court’s Memorandum Opinion in Inv. Research
Associates, Ltd. v. Commissioner, supra, reinstating the
Couvillion report, and directing the parties to file written
objections, followed by responses, to the recommended findings of
fact and conclusions of law contained in the Couvillion report.
On December 16, 2005, respondent filed petitions for panel
rehearing with the Courts of Appeals for the Eleventh and Fifth
Circuits. By order dated January 11, 2006, the Court stayed
further action in the Kanter deficiency cases pending the final
disposition of respondent’s petitions for panel rehearing filed
with the Courts of Appeals for the Eleventh and Fifth Circuits.
Both Courts of Appeals recently denied respondent’s petitions.
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