Legal Opinion

Grant W. Sullivan v. United States

Court of Appeals for the First Circuit

Decided April 18, 1986No. 85-1649PublishedCited by 31 opinions

1Per curiam

Grant Sullivan filed suit in district court against the United States, seeking a refund of his partial payment of a civil penalty that the Internal Revenue Service ■ (IRS) assessed against him, and a determination that the penalty should not have been assessed. The district court dismissed his complaint for failure to state a claim upon which relief could be granted. Sullivan appeals from that dismissal. We affirm.

In April, 1984, Sullivan filed with the IRS a letter entitled “Request for Refund of Income Tax,” and two attached documents entitled “Income Tax Refund Statement for the Tax Year…

2Cases cited14 opinions

  1. Conley v. GibsonSupreme Court of the United States · 1957
  2. Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
  3. United States v. John E. BurasCourt of Appeals for the Ninth Circuit · 1980
  4. Itel Capital Corporation, a Corporation, Cross-Appellant v. Cups Coal Company, Incorporated, a Corporation and Herman Mulvehill, Cross-AppelleesCourt of Appeals for the Eleventh Circuit · 1983
  5. Michael W. Lovell and Phyllis D. Lovell v. United StatesCourt of Appeals for the Seventh Circuit · 1984

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

3Cited by31 opinions

  1. Hall v. BellmonCourt of Appeals for the Tenth Circuit · 1991
  2. Hall v. BellmonCourt of Appeals for the Tenth Circuit · 1991
  3. Callahan v. Comm'rUnited States Tax Court · 2008
  4. Joseph A. Lefebvre v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1987
  5. Ahwinona v. StateAlaska Supreme Court · 1996

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

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