Law Commons^™

Federal Taxation, Dustin M. Covello, Augustus N. Makris

Mercer Law Review

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 …