Ellis Campbell, Jr., District Director of Internal Revenue v. M. F. Guetersloh, Emma Guetersloh, Chris D. Guetersloh, and Viola Guetersloh
Court of Appeals for the Fifth Circuit
1Opinion of the Court
TUTTLE, Chief Judge.
The District Director of Internal Revenue appeals from what appears to be an unprecedented permanent injunction restraining him from using a particular method of computing an alleged deficiency in income taxes.
The taxpayers, two brothers and their wives, complained in their suit for injunction that the Director was threatening to issue a statutory notice of deficiency, commonly known as a 90-day letter asserting deficiencies in their income taxes for calendar years 1947-1951, and fraud penalties, based on “improper, illegal, oppressive, arbitrary, capricious and vicious…
Also in this document: Concurrence.
2Cases cited10 opinions
- Miller v. Standard Nut Margarine Co. of Fla.Supreme Court of the United States · 1932
- Hill v. WallaceSupreme Court of the United States · 1922
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Boyett Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Poncet Davis v. United StatesCourt of Appeals for the Sixth Circuit · 1955
5 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- Condor Merritt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- Harper v. CommissionerUnited States Tax Court · 1970
- Estate of Beck v. Comm'rUnited States Tax Court · 1971
- Louis Sager Hunsucker, Jr. v. Robert L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1974
- Harbin v. CommissionerUnited States Tax Court · 1963
54 more not listed; retrieve them via the Exa API.