Legal Opinion
Rocanova v. United States
District Court, S.D. New York
Decided May 29, 1996No. 95 Civ. 8727(DC)PublishedCited by 12 opinions
1Opinion of the Court
MEMORANDUM DECISION
CHIN, District Judge.
In this action, plaintiff Mark Rocanova seeks a declaration that the retroactive application of § 11317(c) of Public Law 101-508, which revised § 6502 of the Internal Revenue Code by extending the statute of limitations for collection actions from six years to ten years, is unconstitutional. Rocanova bases this argument on the Due Process Clause of the Fifth Amendment, the Equal Protection Clause, and the Ex Post Facto Clause. The parties have cross-moved for summary judgment. Because retroactive application of the ten-year statute of limitations is…
2Cases cited16 opinions
- Harris v. McRaeSupreme Court of the United States · 1980
- United States Trust Co. of NY v. New JerseySupreme Court of the United States · 1977
- Pension Benefit Guaranty Corporation v. RA Gray & Co.Supreme Court of the United States · 1984
- Regan v. Taxation With Representation of WashingtonSupreme Court of the United States · 1983
- Maher v. RoeSupreme Court of the United States · 1977
11 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Boyd v. Comm'rUnited States Tax Court · 2001
- J. Thomas Zaber, On Behalf Of Himself And All Others Similarly Situated Vs. City Of Dubuque, IowaSupreme Court of Iowa · 2010
- BLAK Invs. v. Comm'rUnited States Tax Court · 2009
- BLAK Investments, Kyle W. Manroe Trust, Robert and Lori Manroe, Trustees, Tax Matters Partner v. CommissionerUnited States Tax Court · 2009
- Venable v. Comm'rUnited States Tax Court · 2003
7 more not listed; retrieve them via the Exa API.