Legal Opinion
Wagner v. United States
District Court, E.D. Pennsylvania
Decided July 11, 1979No. Civ. A. 79-2134PublishedCited by 10 opinions
1Opinion of the Court
OPINION
LUONGO, District Judge.
The plaintiffs in this action are taxpayers who seek to enjoin the collection of a federal income tax deficiency assessed for the years 1972 and 1973. They argue that the Internal Revenue Service (IRS) failed to send them a statutory notice of deficiency, as required by I.R.C. §§ 6212(a), 6213(a), and that the IRS should therefore be enjoined both from its present attempts at collection and (since the statute of limitations for those years has run) from any further deficiency assessment for 1972 and 1973. 1
Because the availability of injunctive relief against the…
2Cases cited8 opinions
- Commissioner v. ShapiroSupreme Court of the United States · 1976
- Laing v. United StatesSupreme Court of the United States · 1976
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Roy W. Dewelles v. United States of AmericaCourt of Appeals for the Ninth Circuit · 1967
- Joseph Delman and Jeanette Delman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
3 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- Lewis E. Johnson and Jeanne K. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1980
- Virginia Lime Company v. Craigsville Distributing Company, Inc.Court of Appeals for the Fourth Circuit · 1982
- United States v. PurcellDistrict Court, E.D. Pennsylvania · 1991
- Grafton v. United StatesDistrict Court, W.D. Missouri · 1983
5 more not listed; retrieve them via the Exa API.