Legal Opinion
Friko Corporation, Johnny Daccarett-Ghia, as Alleged Alter Ego or Nominee of Friko Corporation v. Commissioner of Internal Revenue
Court of Appeals for the D.C. Circuit
Decided August 22, 1994No. 93-1269PublishedCited by 19 opinions
1Opinion of the Court
Opinion for the court filed by Circuit Judge RANDOLPH.
RANDOLPH, Circuit Judge:
Ordinarily, the Internal Revenue Service may not collect taxes, said to be due and owing from a taxpayer, until the taxpayer has had a chance to litigate his tax liability in the Tax Court. Commissioner v. Shapiro, 424 U.S. 614, 616-17, 96 S.Ct. 1062, 1065-66, 47 L.Ed.2d 278 (1976). Matters are different if the Commissioner determines that collection of the alleged tax deficiency would be “jeopardized by delay.” 26 U.S.C. § 6861(a). Then the Commissioner may immediately assess the tax, and, if the taxpayer fails to…
2Cases cited14 opinions
- Hughes v. United StatesCourt of Appeals for the Ninth Circuit · 1992
- Ortega-Rodriguez v. United StatesSupreme Court of the United States · 1993
- Commissioner v. ShapiroSupreme Court of the United States · 1976
- United States v. DaccarettCourt of Appeals for the Second Circuit · 1993
- United States v. Pole No. 3172, Hopkinton, Etc., Appeal of Alice Gazda, Ida Ambrosio and Charles FogartyCourt of Appeals for the First Circuit · 1988
9 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Johnny Daccarett-Ghia, Alleged Alter Ego or Nominee of Friko Corporation v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 1996
- I & O Publishing Co., Inc., and Wallace Ward v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1997
- Granse v. United StatesDistrict Court, D. Minnesota · 1995
- Edelman v. CommissionerUnited States Tax Court · 1994
- United States v. Lawrence GenoaCourt of Appeals for the Sixth Circuit · 1995
14 more not listed; retrieve them via the Exa API.