Legal Opinion

U.S.A., Internal Revenue Service v. Teal

Court of Appeals for the Fifth Circuit

Decided February 9, 1994No. 93-8147PublishedCited by 55 opinions

1Per curiam

The Internal Revenue Service challenges the district court’s holding that James Carroll Teal did not owe penalties or associated interest arising out of his 1979 income tax year (1979). We REVERSE.

I

In 1983, Teal filed an amended return for 1979, claiming that, because of a tax shelter, he was entitled to a refund of approximately $13,000. The IRS made the refund, but subsequently notified Teal- (late 1985) that he was liable for it, as well as for four penalties and interest. Teal contested that decision by filing a petition in Tax Court in early 1986. Teal and the IRS agreed to a settlement,…

2Cases cited12 opinions

  1. Federated Department Stores, Inc. v. MoitieSupreme Court of the United States · 1981
  2. Begier v. Internal Revenue ServiceSupreme Court of the United States · 1990
  3. United States v. International Building Co.Supreme Court of the United States · 1953
  4. Kaspar Wire Works, Inc. v. Leco Engineering and MacHine Inc.Court of Appeals for the Fifth Circuit · 1978
  5. United States v. Bernice H. ShanbaumCourt of Appeals for the Fifth Circuit · 1994

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3Cited by55 opinions

  1. Comer v. Murphy Oil USA, Inc.Court of Appeals for the Fifth Circuit · 2013
  2. In Re Clayton Baker Sally I. Baker, Debtors. Clayton Baker Sally I. Baker v. Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1996
  3. Northbrook Partners LLP v. County of Hennepin (In Re Northbrook Partners LLP)United States Bankruptcy Court, D. Minnesota · 2000
  4. Crest-Mex Corp. v. County of Dallas (In Re Crest-Mex Corp.)United States Bankruptcy Court, S.D. Texas · 1998
  5. In Re: Roger E. Mantz and Sandra J. Mantz, Roger E. Mantz Sandra J. Mantz v. California State Board of EqualizationCourt of Appeals for the Ninth Circuit · 2003

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