Legal Opinion
Barrister Associates v. United States
Court of Appeals for the Second Circuit
Decided March 22, 1993No. Nos. 1376, 1405 and 1406, Dockets 91-6289, 91-6291 and 91-6317PublishedCited by 4 opinions
1Opinion of the Court
WINTER, Circuit Judge:
This is an action for a refund of penalties paid to the Internal Revenue Service (“IRS”) pursuant to Internal Revenue Code (“I.R.C.”) § 6700 (1982). In 1986, the IRS assessed penalties against each of the appellants for promoting and organizing allegedly abusive tax shelters. After paying fifteen percent of the assessments, appellants filed suit for a refund, pursuant to I.R.C. § 6703 (1982). The government counterclaimed for payment of the remaining eighty-five percent of the penalties assessed.
On July 11, 1990, following a jury trial before Chief Judge Platt, each of…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Bixby v. CommissionerUnited States Tax Court · 1972
- United States v. CartwrightSupreme Court of the United States · 1973
- Siegel v. CommissionerUnited States Tax Court · 1982
19 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- In Re Mdl-731--Tax Refund Litigation Of Organizers And Promoters Of Investment Plans Involving Book Properties Leasing. Barrister AssociatesCourt of Appeals for the Second Circuit · 1993
- John Crim v. Cmsnr. IRSCourt of Appeals for the D.C. Circuit · 2023
- Ginsburg v. United StatesUnited States Court of Federal Claims · 2018
- Ginsburg v. United StatesUnited States Court of Federal Claims · 2018