Legal Opinion

Richard H. Jenney and Judy Harden Jenney v. United States

Court of Appeals for the Ninth Circuit

Decided March 18, 1985No. CA 84-5949PublishedCited by 17 opinions

1Opinion of the Court

SOLOMON, Senior District Judge:

Taxpayers filed an action to challenge a $500 civil penalty imposed against them by the Internal Revenue Service (IRS) for claiming a “conscience deduction” in their 1982 federal income tax return. The district court granted summary judgment in favor of taxpayers, 581 F.Supp. 1309, and the government appealed. We reverse.

Facts

Taxpayers, husband and wife, timely filed a joint 1982 federal income tax return on Form 1040. They reported total income of $56,679. On a Schedule A attached to the return, taxpayers reported itemized deductions of $24,382. Schedule A…

2Cases cited6 opinions

  1. Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
  2. Neila A. Autenrieth v. Joseph M. Cullen, District Director of IrsCourt of Appeals for the Ninth Circuit · 1969
  3. Kahn, Emily v. United StatesCourt of Appeals for the Third Circuit · 1985
  4. Heiniger v. City of PhoenixCourt of Appeals for the Ninth Circuit · 1980
  5. Sharon D. Welch v. United StatesCourt of Appeals for the First Circuit · 1985

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

3Cited by17 opinions

  1. All Hawaii Tours, Corp. v. Polynesian Cultural CenterDistrict Court, D. Hawaii · 1987
  2. Priscilla M. Lippincott Adams v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1999
  3. Daniel Taylor Jenkins v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Second Circuit · 2007
  4. Allen W. Jolly v. United StatesCourt of Appeals for the Ninth Circuit · 1985
  5. Martin S. Bradley v. United StatesCourt of Appeals for the Ninth Circuit · 1987

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

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