Legal Opinion

Martin S. Bradley v. United States

Court of Appeals for the Ninth Circuit

Decided May 22, 1987No. 85-2445PublishedCited by 26 opinions

1Opinion of the Court

CHOY, Senior Circuit Judge:

Martin Bradley appeals the district court’s grant of summary judgment in favor of the Government, upholding a $500 frivolous return penalty assessed by the Internal Revenue Service (“IRS”) against Bradley pursuant to I.R.C. § 6702. 1 This appeal raises the novel question of whether a section 6702 penalty may be assessed against an individual who, though not legally obligated to file a tax return or pay tax, submits a Form 1040 to the IRS which states that no tax will be paid for reasons of conscience. We conclude that a section 6702 penalty may be assessed in such a…

2Cases cited14 opinions

  1. United States v. O'BrienSupreme Court of the United States · 1968
  2. Commissioner v. AckerSupreme Court of the United States · 1959
  3. Kahn, Emily v. United StatesCourt of Appeals for the Third Circuit · 1985
  4. United States v. Ronald M. LongCourt of Appeals for the Ninth Circuit · 1980
  5. United States v. Herbert L. HorneCourt of Appeals for the First Circuit · 1983

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

3Cited by26 opinions

  1. Donna L. Todd v. United States of America and R.S. Wintrode, Jr., District Director, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
  2. Lorin G. Sloan v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1995
  3. United States v. Ted H. KimballCourt of Appeals for the Ninth Circuit · 1991
  4. Waltner v. United StatesUnited States Court of Federal Claims · 2011
  5. United States v. Jane BoydCourt of Appeals for the Ninth Circuit · 2021

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

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