Legal Opinion

Randall S. Goulding v. United States

Court of Appeals for the Seventh Circuit

Decided March 18, 1992No. 90-1788PublishedCited by 16 opinions

1Opinion of the Court

RIPPLE, Circuit Judge.

Randall Goulding was retained to act as the attorney for several limited partnerships. Mr. Goulding prepared the partnership returns and the Schedules K-l for each partnership. Under Treasury Regulation § 301.7701-15(b)(3), the IRS deemed Mr. Goulding the preparer of the returns of the limited partners and assessed penalties against Mr. Goulding under 26 U.S.C. § 6694 for the negligent preparation of those returns. Mr. Goulding challenged the penalties in the district court, and the district court upheld them. For the reasons set forth in this opinion, we affirm the…

2Cases cited16 opinions

  1. United States v. CorrellSupreme Court of the United States · 1967
  2. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
  3. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  4. Zenith Radio Corp. v. United StatesSupreme Court of the United States · 1978
  5. Commissioner v. AckerSupreme Court of the United States · 1959

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

3Cited by16 opinions

  1. Stephen P. Wilfong v. United StatesCourt of Appeals for the Seventh Circuit · 1993
  2. United States v. Randall S. Goulding and Michael M. UshijimaCourt of Appeals for the Seventh Circuit · 1994
  3. Edward J. Richardson v. Commissioner of Internal Revenue, Irene E. Richardson v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1997
  4. Adler & Drobny, Ltd. And Sheldon Drobny v. United StatesCourt of Appeals for the Seventh Circuit · 1993
  5. United States v. ElsassDistrict Court, S.D. Ohio · 2013

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

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