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FELDMAN v. C.I.R.

No. 93-4519.

20 F.3d 1128 (1994)

Donald FELDMAN and Patricia Feldman, a/k/a Patsy Jane Feldman, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

May 17, 1994.

Attorney(s) appearing for the Case

Donald Feldman, pro se.

Gary R. Allen, Chief, Paula K. Speck, Jonathan S. Cohen, Appellate Section, Tax Div., Dept. of Justice, Washington, DC, for appellee.

Before TJOFLAT, Chief Judge, DUBINA, Circuit Judge, and RONEY, Senior Circuit Judge.

DUBINA, Circuit Judge:

This appeal concerns a notice of deficiency disallowing deductions arising out of appellants' ("the Feldmans") investments in three tax shelter limited partnerships. The Feldmans, husband and wife, do not contest the merits of these deficiencies and penalties, but argue that they are barred by the statute of limitations and that Patricia Feldman should receive innocent spouse relief under 26 U.S.C. § 6013(e).1

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