Legal Opinion
Syufy v. United States
District Court, N.D. California
Decided January 21, 1986No. C-84-1084 RHSPublishedCited by 2 opinions
1Opinion of the Court
ORDER
SCHNACKE, District Judge.
On January 3,1986, this Court: (a) held a hearing on plaintiffs’ summary judgment *1283motion; and (b) took the motion under submission.
This civil action arises out of the 1983 assessment, by defendant’s Internal Revenue Service, of excise taxes, penalties, and interest against plaintiffs. The complaint, as amended, prays for: (a) return of the $13,750 already paid on the assessment; and (b) abatement of the rest of the assessment. Defendant counterclaims for the rest of the assessment.
The assessment is based on a Bahamian trust’s 1972 receipt, from plaintiff Raymond…
2Cases cited2 opinions
- Werner Abegg v. Commissioner of Internal Revenue, Cresta Corporation, S.A., Transferee v. Commissioner of Intenal RevenueCourt of Appeals for the Second Circuit · 1970
- Stern v. United StatesDistrict Court, D. Nevada · 1983
3Cited by2 opinions
- Sidney v. United StatesDistrict Court, D. Nevada · 1986
- Raymond Syufy Marcia Syufy, Plaintiffs-Counterclaim v. United States of America, Defendant-Counterclaimant-AppellantCourt of Appeals for the Ninth Circuit · 1987