Legal Opinion
Bruce Morgan v. United States
Court of Appeals for the Ninth Circuit
Decided March 11, 1992No. 90-16641PublishedCited by 9 opinions
1Per curiam
Federal agents seized $191,900 in cash Morgan was carrying in his luggage when he landed at Oakland airport. He has never acknowledged ownership of the money. The IRS made a deficiency determination of $53,732 pursuant to section 6851(a), which provides for termination of the taxable year and immediate determination of the tax due, and section 6861(a), which authorizes immediate assessment of tax when collection will be jeopardized by delay.1 In so doing, the IRS relied on a statutory presumption that collection of tax on cash amounts in excess of $10,000 held by persons who do not claim…
2Cases cited7 opinions
- Loretto v. United StatesDistrict Court, E.D. Pennsylvania · 1977
- Stebco Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1990
- Carlos Zuluaga v. United StatesCourt of Appeals for the Ninth Circuit · 1985
- Commissioner of Internal Revenue, Petitioner-Cross-Respondent v. Leon E. Hendrickson, Respondent-Cross-Petitioner, and Peoples Loan & Trust CompanyCourt of Appeals for the Seventh Circuit · 1989
- Albert Matut, as the Possessor of Certain Cash v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1988
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- American Greyhound Racing, Inc. v. HullDistrict Court, D. Arizona · 2001
- Friko Corporation, Johnny Daccarett-Ghia, as Alleged Alter Ego or Nominee of Friko Corporation v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1994
- Erma Stites v. United StatesCourt of Appeals for the Ninth Circuit · 1992
- Erma Stites v. United StatesCourt of Appeals for the Ninth Circuit · 1992
- Allison Barkley v. City of SouthfieldMichigan Court of Appeals · 2026
4 more not listed; retrieve them via the Exa API.