Legal Opinion
Franklin v. United States
District Court, E.D. Michigan
Decided March 16, 1984No. Civ. A. 83CV-6445-AAPublishedCited by 8 opinions
1Opinion of the Court
ORDER
JOINER, District Judge.
This matter is before the Court on the respondent’s motion to dismiss the petition to quash an IRS summons. The motion has been considered on the papers filed and without oral argument pursuant to Fed.R. Civ.P. 78 and Local Rule 17(j).
Congress recently changed the procedures for challenging Internal Revenue summons issued to statutory third-party recordkeepers when it enacted the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). Under the new procedure, in order to challenge an IRS summons by a petition to quash, the taxpayer must file an action within 20…
2Cited by8 opinions
- Wall Industries, Inc. v. United StatesUnited States Court of Claims · 1986
- Clay v. United StatesCourt of Appeals for the Sixth Circuit · 1999
- George M. Stringer v. United States of America, and Ira G. Chambless, Internal Revenue Agent, Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1985
- Dame v. United StatesDistrict Court, S.D. New York · 1986
- Cosme v. Internal Revenue ServiceDistrict Court, E.D. New York · 1989
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