Taxation-Federal Commons^™

Federal Taxation, Michael H. Plowgian, Svetoslav S. Minkov, Mark S. Davis

Mercer Law Review

While the legal holdings of the tax cases decided in the Eleventh Circuit in 2006 do not appear remarkable at first blush, the cases present somewhat conflicting considerations of equity that make them noteworthy. The Eleventh Circuit held in Ellinger v. United States that a taxpayer, who owned half of the stock in three S corporations, could not rely on language in a closing agreement between the Internal Revenue Service (the "Service") and one of the corporations to determine his tax liability with respect to transactions between the first corporation and the other two corporations. Reversing a district court decision, …