Legal Opinion
Ronald L. Pack, and Marla Pack, for Themselves and as Representatives of a Class v. United States
Court of Appeals for the Ninth Circuit
Decided May 5, 1993No. 92-16837PublishedCited by 18 opinions
1Opinion of the Court
T.G. NELSON, Circuit Judge:
I
OVERVIEW
In order to resolve a dispute with the Internal Revenue Service (IRS) regarding the tax treatment of certain partnership property, Ronald and Marla Pack (the Packs) executed a closing agreement with the IRS. The Packs filed this suit against the United States (Government) seeking a tax refund for interest assessed on their tax deficiency. They contend that the closing agreement suspended the assessment of- interest and that they are entitled to a refund of the interest they paid.
The district court had jurisdiction under 28 U.S.C. § 1346. We have…
2Cases cited7 opinions
- Ardestani v. Immigration & Naturalization ServiceSupreme Court of the United States · 1991
- Love v. United StatesCourt of Appeals for the Ninth Circuit · 1989
- Ruth E. Oscar Charles Spinosa v. University Students Co-Operative Association George ProperCourt of Appeals for the Ninth Circuit · 1992
- Zaentz v. CommissionerUnited States Tax Court · 1988
- William W. Boyd and Ruth G. Boyd v. United StatesCourt of Appeals for the Ninth Circuit · 1985
2 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Kearney v. Foley & Lardner, LLPCourt of Appeals for the Ninth Circuit · 2009
- John M. Quarty, Personal Representative of the Estate of Angele C. Quarty Elizabeth B. Cherne v. United StatesCourt of Appeals for the Ninth Circuit · 1999
- Thacker v. Federal Communications Commission (In Re Magnacom Wireless, LLC)Court of Appeals for the Ninth Circuit · 2007
- International Paper Co. v. United StatesUnited States Court of Federal Claims · 1996
- Brookes v. CommissionerUnited States Tax Court · 1997
13 more not listed; retrieve them via the Exa API.