Legal Opinion

Gens v. United States

United States Court of Claims

Decided February 20, 1980No. 77-74; No. 78-74PublishedCited by 49 opinions

1Opinion of the CourtSmith, Judge

In this consolidated action, plaintiffs sue for refund of income taxes overpaid for the years 1968, 1970, and 1971, which overpayments the Commissioner of Internal Revenue applied to satisfy certain 100-percent penalty assessments made against plaintiff Richard Gens pursuant to section 6672 of the Internal Revenue Code of 1954,1 and for refund of token payments made by plaintiff Richard Gens2 with respect to certain other 100-percent penalty assessments. The Government has filed a counterclaim for the *410unpaid portion of the penalty assessments and for interest assessments made with respect to…

2Cases cited7 opinions

  1. Acme Harvester Co. v. Beekman Lumber Co.Supreme Court of the United States · 1912
  2. Robert White v. The United StatesUnited States Court of Claims · 1967
  3. Terrance M. Kelly v. George O. Lethert, as District Director of Internal Revenue, District of MinnesotaCourt of Appeals for the Eighth Circuit · 1966
  4. Rosen v. United StatesDistrict Court, E.D. Pennsylvania · 1975
  5. Crompton-Richmond Co. v. United StatesDistrict Court, S.D. New York · 1970

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

3Cited by49 opinions

  1. Anthony A. Calderone, Clark Hornbaker, Plaintiffs-Counterclaim Defendants v. United States of America, Defendant-Counter-Claimant-AppellantCourt of Appeals for the Sixth Circuit · 1986
  2. Uslife Title Insurance Company of Dallas on Behalf of Lillian v. Mathews v. Paul R. Harbison v. United States of America Acting by and Through the Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1986
  3. Jahn v. ReganDistrict Court, E.D. Michigan · 1984
  4. Internal Revenue Service v. BlaisDistrict Court, D. Massachusetts · 1985
  5. McClelland v. MassingaCourt of Appeals for the Fourth Circuit · 1986

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

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