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Freytag v. Commissioner of Internal Revenue
United States Supreme Court
501 U.S. 868 (1991)
The commissioner of internal revenue (commissioner) (defendant) issued deficiency notices against Freytag and other federal taxpayers (plaintiffs). The plaintiffs petitioned the United States Tax Court for a redetermination. The chief judge of the tax court appointed a special trial judge to preside over the hearing, and then adopted the special trial judge’s opinion in favor of the commissioner. The plaintiffs appealed. The United States Court of Appeals for the Fifth Circuit affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Blackmun, J.)
Concurrence (Scalia, J.)
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