Legal Opinion

Charles H. Stubbs v. Commissioner of Internal Revenue Service

Court of Appeals for the Eleventh Circuit

Decided August 25, 1986No. 85-8447PublishedCited by 35 opinions

Non-Argument Calendar.

1Per curiam

Stubbs appeals the tax court’s grant of summary judgment in favor of the Commissioner of Internal Revenue Service (“Commissioner”) on Stubbs’ liability for tax deficiencies and penalties for the years 1976 through 1980. The tax court may grant summary judgment if “there is no genuine issue as to any material fact and ... a decision may be rendered as a matter of law.” Tax Court Rule 121(b). Summary judgment may be based on “the pleadings, ... admissions, and any other acceptable materials, together with the affidavits.” Id.

The tax court’s grant of summary judgment in this case was based upon…

2Cases cited9 opinions

  1. Baker v. CarrSupreme Court of the United States · 1962
  2. United States v. SullivanSupreme Court of the United States · 1927
  3. Zicarelli v. New Jersey State Commission of InvestigationSupreme Court of the United States · 1972
  4. Leser v. GarnettSupreme Court of the United States · 1922
  5. Brookhaven Landscape & Grading Co., Inc. v. J. F. Barton Contracting Company and United States Fidelity and Guaranty Co.Court of Appeals for the Eleventh Circuit · 1982

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3Cited by35 opinions

  1. Petzoldt v. CommissionerUnited States Tax Court · 1989
  2. Carney v. Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 2001
  3. Buser v. United StatesUnited States Court of Federal Claims · 2009
  4. United States v. George S. SitkaCourt of Appeals for the Second Circuit · 1988
  5. Nick-O-Val Music Co., Inc. v. POS Radio, Inc.District Court, M.D. Florida · 1987

30 more not listed; retrieve them via the Exa API.

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