Smith v. United States
Court of Appeals for the Tenth Circuit
1Opinion of the Court
BRISCOE, Circuit Judge.
Plaintiff-Appellant Richard A. Smith filed a complaint in the district court pursuant to 28 U.S.C. § 1346(a)(1), seeking a refund of amounts paid in partial satisfaction of Internal Revenue Service (“IRS”) assessments. Smith alleged the assessments were erroneously and illegally made because he was not a “responsible person” as defined by 26 U.S.C. § 6672. Defendant-Appellee United States filed an answer and counterclaim for amounts still owed. The ease proceeded to jury trial. At the close of his presentation of evidence, Smith moved for judgment as a matter of law,…
2Cases cited15 opinions
- Slodov v. United StatesSupreme Court of the United States · 1978
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- John O. Denbo, Plaintiff-Counterclaim v. United States of America, Defendant-Counterclaim v. Robert B. Allred, CounterclaimCourt of Appeals for the Tenth Circuit · 1993
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