Legal Opinion

Donald Sherman v. Roland H. Nash, District Director of Internal Revenue

Court of Appeals for the Third Circuit

Decided November 27, 1973No. 72-1607PublishedCited by 6 opinions

1Opinion of the Court

OPINION OF THE COURT

James HUNTER, III, Circuit Judge:

Appellants, Donald and Marcia Sherman, sought in the district court injunc-tive relief from a jeopardy assessment imposed upon them by the District Director of Internal Revenue (“District Director”).1 The district court held that it was without jurisdiction to review the decision of the District Director. This appeal followed pursuant to the jurisdiction granted this court by 28 U.S.C. § 1291. We reverse.

On April 7, 1971, there was delivered to the Shermans’ New Jersey residence a demand for payment of taxes and notification that the…

2Cases cited3 opinions

  1. Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
  2. United States v. BonaguroDistrict Court, E.D. New York · 1968
  3. Iannelli v. LongCourt of Appeals for the Third Circuit · 1973

3Cited by6 opinions

  1. Flynn, M. Rutledge v. United States of America by and Through Eggers, Roscoe Commissioner of Internal Revenue. Appeal of M. Rutledge FlynnCourt of Appeals for the Third Circuit · 1986
  2. Henry Thornton v. United States of America, and Alfred L. Whinston, District Director of Internal RevenueCourt of Appeals for the Third Circuit · 1974
  3. United States v. Mellon Bank, N. A., Appeal of Milton F. Meissner, Intervenor-RespondentCourt of Appeals for the Third Circuit · 1975
  4. Westgate-California Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1974
  5. Stone v. United StatesDistrict Court, S.D. New York · 1975

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