Legal Opinion

Michael W. Lovell and Phyllis D. Lovell v. United States

Court of Appeals for the Seventh Circuit

Decided December 18, 1984No. 84-1547PublishedCited by 60 opinions

1Per curiam

Plaintiffs appeal from a district court order granting summary judgment to the government and assessing a $500 frivolous return penalty under 26 U.S.C.A. § 6702(a). The district court also awarded attorneys’ fees to the government because plaintiffs’ legal position was patently frivolous. 579 F.Supp. 1047 (D.Wis.) We affirm.

I

In April 1983, plaintiffs filed separate Forms 1040 for the 1982 tax year. Each plaintiff claimed no income from wages or salaries during 1982, although each claimed a refund of all the federal income and Social Security taxes that had been withheld during the year. The…

2Cases cited13 opinions

  1. Glenn Crain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
  2. Margarito Martinez, Patricia Martinez v. Internal Revenue ServiceCourt of Appeals for the Tenth Circuit · 1984
  3. United States v. Thomas J. KoliboskiCourt of Appeals for the Seventh Circuit · 1984
  4. Alton M. Parker, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
  5. Melvin Davis and Maria T. Davis v. United States Government and Irs Director, Austin, TexasCourt of Appeals for the Fifth Circuit · 1984

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

3Cited by60 opinions

  1. Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986
  2. Charles William Ledford v. United StatesCourt of Appeals for the Federal Circuit · 2002
  3. United States v. Roy W. CollinsCourt of Appeals for the Tenth Circuit · 1990
  4. In Re Lowell H. Becraft, Jr. United States of America v. Kenneth W. NelsonCourt of Appeals for the Ninth Circuit · 1989
  5. United States v. Lorin G. SloanCourt of Appeals for the Seventh Circuit · 1991

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

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