Legal Opinion
Paul Retfalvi v. United States
Court of Appeals for the Fourth Circuit
Decided July 16, 2019No. 18-2158PublishedCited by 236 opinions
1Opinion of the Court
HOLLANDER, District Judge:
This appeal resolves a challenge to the constitutionality of a treaty authorizing the United States to collect unpaid income taxes on behalf of Canada. The issue arises in the context of a tax refund action filed by appellant Paul M. Retfalvi, M.D., the taxpayer. He filed suit against the United States, seeking a refund of approximately $125,000 in taxes collected from him by the Internal Revenue Service ("IRS"), pursuant to the treaty, for income taxes that he owed to Canada for 2006.
Dr. Retfalvi advances several grounds in support of his challenge to the…
2Cases cited27 opinions
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