Allen v. United States
Court of Appeals for the Eleventh Circuit
Non-Argument Calendar.
1Opinion of the Court
KRAVITCH, Circuit Judge:
The Commissioner of Internal Revenue offset the refund of a fraud penalty, improperly imposed on Allen, with new negligence and delinquency penalties for the same tax year. Allen sued for the balance; the district court concluded that the Commissioner’s action was proper and denied the refund. We agree and AFFIRM.
I
The material facts are not in dispute. Appellant Allen refused to pay his income taxes for the 1975 and 1976 tax years, submitting “protest” documents in lieu of the required returns. Allen was convicted for willful failure to file federal income tax returns…
2Cases cited13 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Kotmair v. CommissionerUnited States Tax Court · 1986
- Loftin & Woodard, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1978
- Samuel C. Dysart and Alma R. Dysart v. The United StatesUnited States Court of Claims · 1965
8 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Bachner v. CommissionerUnited States Tax Court · 1997
- Gisele C. Fisher v. United StatesCourt of Appeals for the Federal Circuit · 1996
- Sprint Communications Co. v. State Board of EqualizationCalifornia Court of Appeal · 1995
- Wells Fargo & Company v. United StatesCourt of Appeals for the Eighth Circuit · 2020
- Bachner v. CommissionerUnited States Tax Court · 1997
2 more not listed; retrieve them via the Exa API.