Legal Opinion
Swart v. United States
District Court, C.D. California
Decided April 20, 1982No. CV 81-3318 AWTPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OPINION
TASHIMA, District Judge.
This is an action for refund of a $100.00 penalty which was imposed upon plaintiff by the Internal Revenue Service (“I.R.S.”), for negligent disregard of I.R.S. rules and regulations, in violation of 26 U.S.C. § 6694. 1 2 Federal jurisdiction is properly in voked under 28 U.S.C. § 1346(a)(1). Discovery is complete and defendant now moves for summary judgment. Rule 56(b), Fed.R.Civ.P. After consideration of the written record, as well as the oral arguments of counsel, I find that there are no controverted issues of material fact and that defendant is…
2Cases cited7 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Adam G. Nunez v. The Superior Oil CompanyCourt of Appeals for the Fifth Circuit · 1978
- Clifford F. Mack and Helen L. Mack v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
- Daniel Henry Arney and Charles H. Baker v. United States of AmericaCourt of Appeals for the Ninth Circuit · 1973
- Oren F. Potito, Oren F. Potito and Helen M. Potito v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- United States v. BaileyDistrict Court, N.D. Texas · 1992
- Wick v. Tucson Newspaper, Inc.District Court, D. Arizona · 1985
- Weidmann v. U.S. Department of TreasuryDistrict Court, W.D. New York · 1989