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Jeffrey Lefcourt and Ruth Anne Lefcourt v. Commissioner of Internal Revenue

Citations: 925 F.2d 399; 1991 U.S. App. LEXIS 3255; 1991 WL 17248Docket: 90-5465

Court: Court of Appeals for the Eleventh Circuit; March 4, 1991; Federal Appellate Court

Narrative Opinion Summary

The case involves Jeffrey and Ruth Anne Lefcourt, who appealed a decision from the Tax Court regarding the retroactive application of a 1984 statutory amendment related to investment tax credit recapture. The Eleventh Circuit Court of Appeals, referencing the precedent set in Wiggins v. Commissioner of Internal Revenue, affirmed the Tax Court's judgment. The court did not provide additional commentary, and the ruling was unanimous among the judges involved. The appeal was represented by Howard W. Gordon for the Lefcourts and a team from the U.S. Department of Justice for the IRS.

Legal Issues Addressed

Precedential Authority in Tax Law

Application: The court referenced the precedent set in Wiggins v. Commissioner of Internal Revenue to affirm its judgment, demonstrating reliance on established legal authority in tax-related matters.

Reasoning: The Eleventh Circuit Court of Appeals, referencing the precedent set in Wiggins v. Commissioner of Internal Revenue, affirmed the Tax Court's judgment.

Retroactive Application of Statutory Amendments

Application: The Eleventh Circuit Court of Appeals affirmed the Tax Court's decision on the retroactive application of the 1984 statutory amendment related to investment tax credit recapture, indicating the amendment was applicable to the case at hand.

Reasoning: The case involves Jeffrey and Ruth Anne Lefcourt, who appealed a decision from the Tax Court regarding the retroactive application of a 1984 statutory amendment related to investment tax credit recapture.