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Publication Date

7-2010

Document Type

Survey Article

Abstract

This Article surveys the limited number of significant federal tax cases decided by courts in the Eleventh Circuit in 2009. In Commissioner v. Neal, the United States Court of Appeals for the Eleventh Circuit became the first circuit court of appeals to examine whether the United States Tax Court was required to conduct a trial de novo when a taxpayer appealed the Internal Revenue Service's denial of relief under I.R.C. § 6015. In Nero Trading, LLC v. United States, the Eleventh Circuit addressed the nature of the hearing a district court must provide to a taxpayer who challenges a summons from the Service before the district court may enforce such a summons. In United States v. UBS AG, the United States District Court for the Southern District of Florida denied a motion by the Swiss bank UBS AG in the ongoing controversy surrounding the United States government's efforts to force the bank to release the names of account holders suspected of tax evasion. In United States v. Klohn, the United States District Court for the Middle District of Florida addressed the period within which a taxpayer may claim a credit or refund of an overpayment of tax. The case of In re Willis involved whether an individual's actions with respect to his individual retirement accounts (IRAs) disqualified the IRAs from bankruptcy exemption.

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