DISCLAIMER:  The following unofficial case summaries are prepared by the clerk's office
                        as a courtesy to the reader. They are not part of the opinion of the court.

052466P.pdf   03/06/2006  Jefferson Smurfit  v.  United States
   U.S. Court of Appeals Case No:  05-2466
   Eastern District of Missouri   
   [PUBLISHED] [Murphy, Author, with Fagg and Smith, Circuit Judges]
   Civil case - Federal tax. Congress did not intend for a final Tax Court
   decision for the carryback year to bar the IRS from assessing a deficiency
   based on an erroneously carried back amount.