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INVERWORLD LTD. v. C.I.R.

No. 92-1058.

979 F.2d 868 (1992)

INVERWORLD, LTD., Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided November 24, 1992.

Attorney(s) appearing for the Case

T. Barry Kingham, New York City, with whom Samuel Rosenthal, Washington, D.C., was on the brief, for appellant.

Kenneth L. Greene, Attorney, Dept. of Justice, with whom Shirley D. Peterson, Asst. Atty. Gen., and Gary R. Allen, Atty., Dept. of Justice, Washington, D.C., were on the brief for appellee.

Before MIKVA, Chief Judge, WALD and EDWARDS, Circuit Judges.

Opinion for the Court filed by Circuit Judge WALD.

Opinion concurring in part and concurring in the judgment filed by Chief Judge MIKVA.

WALD, Circuit Judge:

InverWorld, Ltd. ("InverWorld"), a Cayman Islands corporation, appeals a decision of the Tax Court denying leave to amend its petition to redetermine tax deficiencies in order to specifically contest corporate income tax deficiencies for 1984, 1985, and 1986. Because InverWorld's motion was made...

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