Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
Wilford L. Severance v. Commissioner of Internal Revenue, Mary E. Severance v. Commissioner of Internal Revenue
Citations: 10 F.3d 810; 1993 U.S. App. LEXIS 38091Docket: 93-9012
Court: Court of Appeals for the Tenth Circuit; November 25, 1993; Federal Appellate Court
Petitioners Wilford L. Severance and Mary E. Severance appealed a Tax Court order determining tax deficiencies and additions. They sought emergency injunctive relief but the Tenth Circuit Court of Appeals found it lacked jurisdiction over the appeals. The Tax Court's final order was issued on December 30, 1992, and the petitioners filed a "Motion for Reconsideration to Vacate" on April 28, 1993, which was not timely under Tax Court Rules. The Court reaffirmed that a notice of appeal must be filed within ninety days after a Tax Court decision, and the time for appeal is only extended if a timely motion to vacate is filed within thirty days. Since the petitioners' motions were filed after the appeal period had expired, their notices of appeal were deemed untimely. Consequently, the appeals were dismissed, and the motions for injunctive relief and to vacate the Tax Court judgment were denied. The order emphasized that this decision has no precedential value and cannot be cited, except for establishing specific legal doctrines.