Legal Opinion
Smoky Mountain Secrets, Inc. v. United States
District Court, E.D. Tennessee
Decided September 28, 1995No. 3:94-cv-00121PublishedCited by 6 opinions
1Opinion of the Court
MEMORANDUM OPINION
JARVIS, District Judge.
This is a tax refund action brought by the plaintiff-taxpayer, Smoky Mountain Secrets, Inc. (SMS), pursuant to 28 U.S.C. § 1346(a)(1). Plaintiff seeks a refund of Form 941, Federal Insurance Contribution Act (FICA) taxes and Form 940, Federal Unemployment Tax Act (FUTA) taxes, which plaintiff contends were assessed erroneously by the United States Department of the Treasury through the Internal Revenue Service (IRS). The total amount of taxes assessed 1 is approximately $3,888,918. This does not include interest on the assessments. The jurisdiction of…
2Cases cited13 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Alfred M. Sinder, Cross-Appellee v. United States of America, Cross-Appellant, and Angelo Ventrone, Third-PartyCourt of Appeals for the Third Circuit · 1981
- General Investment Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1987
- United States v. Roderick J. MacKenzie Malcolm L. MacKenzie and David H. MacKenzie Inc.Court of Appeals for the Second Circuit · 1986
- Diana T. Vorsheck John P. Vorsheck v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1991
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3Cited by6 opinions
- Dixon v. CommissionerUnited States Tax Court · 2013
- 863 To Go, Inc. v. Department of LaborSupreme Court of Vermont · 2014
- Westgate Smoky Mountains at Gatlinburg v. Burns Phillips, Commissioner, Tennessee Department of Labor and Workforce DevelopmentTennessee Supreme Court · 2013
- Dixon v. CommissionerUnited States Tax Court · 2013
- James R. Dixon v. CommissionerUnited States Tax Court · 2013
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