Legal Opinion
Thalia Kelley Considine, and Charles Ray Considine v. United States
Court of Appeals for the Ninth Circuit
Decided August 13, 1982No. 80-5676PublishedCited by 51 opinions
1Opinion of the Court
J. BLAINE ANDERSON, Circuit Judge:
Considine appeals from summary judgment entered in favor of the Government in his tax refund suit. He contends that the district court erred in holding that his prior conviction for filing a false return collaterally estopped him from contesting liability for a civil fraud penalty. We affirm, although for reasons different from those relied on by the district court.
FACTS
Charles and Thalia Considine filed a joint tax return for 1965 showing $8,701 interest income. In 1972, Charles Considine was convicted of willfully filing false tax returns for 1965-67 and…
2Cases cited17 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Pullman-Standard v. SwintSupreme Court of the United States · 1982
- Yates v. United StatesSupreme Court of the United States · 1957
- United States v. BishopSupreme Court of the United States · 1973
- Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
12 more not listed; retrieve them via the Exa API.
3Cited by51 opinions
- Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Wright v. CommissionerUnited States Tax Court · 1985
- Compton v. IdeCourt of Appeals for the Ninth Circuit · 1984
- Paul F. Gray, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1983
- James A. Pittman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
46 more not listed; retrieve them via the Exa API.