Legal Opinion
Diversified Group Inc. v. United States
Court of Appeals for the Federal Circuit
Decided November 10, 2016No. 2016-1014PublishedCited by 22 opinions
1Opinion of the Court
PROST, Chief Judge.
Diversified Group Incorporated (“Diversified”) and its president, Janies Haber, (collectively, “Appellants”) brought this action against the United States, seeking a refund of payments made toward a federal tax penalty which the Internal Revenue Service (“IRS”) assessed under 26 U.S.C. § 6707 for failure to comply with tax shelter registration requirements under 26 U.S.C. § 6111. The United States Court of Federal Claims (“Claims Court”) held that it lacked jurisdiction over the case because Appellants did not comply with the full payment rule. For the reasons stated below,…
2Cases cited17 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- Trusted Integration, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2011
- John G. Rocovich, Jr. v. The United StatesCourt of Appeals for the Federal Circuit · 1991
- Sig and Barbara Shore v. United StatesCourt of Appeals for the Federal Circuit · 1993
- United States v. Kellogg (In Re West Texas Marketing Corp.)Court of Appeals for the Fifth Circuit · 1994
12 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- William Canada, Jr. v. USA (IRS)Court of Appeals for the Fifth Circuit · 2020
- percipient.ai, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2024
- Etchegoinberry v. United StatesCourt of Appeals for the Federal Circuit · 2025
- United States v. Canada (In re Canada)District Court, N.D. Texas · 2017
- Noffke v. United StatesUnited States Court of Federal Claims · 2016
17 more not listed; retrieve them via the Exa API.