Legal Opinion
Hirshfield v. United States
District Court, S.D. New York
Decided November 19, 2001No. 99 CIV. 1828(RWS)PublishedCited by 3 opinions
1Opinion of the Court
OPINION
SWEET, District Judge.
Plaintiff Stuart Hirshfield and his wife, Susanne Hirshfield (the “Hirshfields”), have moved under Local Civil Rule 6.3 for reconsideration of the opinion of this Court dated May 30, 2001 (the “Opinion”), holding that it had no jurisdiction to consider their claim that the IRS notice for penalty and related interest was time-barred and that it was subject to the doctrine of res judicata. For the reasons set forth below, reconsideration is granted, and upon reconsideration partial summary judgment is granted in favor of the Hirshfields.
The “intricate web of…
2Cases cited12 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
- Mercoid Corp. v. Mid-Continent Investment Co.Supreme Court of the United States · 1944
- Russell v. PlaceSupreme Court of the United States · 1877
7 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Kevin Conway v. United StatesCourt of Appeals for the Federal Circuit · 2003
- Daniel L. Carroll and Ingrid N. Carroll, Plaintiffs-Appellees-Cross-Appellants v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Second Circuit · 2003
- Hirshfield v. United StatesCourt of Appeals for the Second Circuit · 2003