Legal Opinion
Berkery v. United States
District Court, E.D. Pennsylvania
Decided April 22, 1982No. Civ. A. 82-862PublishedCited by 7 opinions
1Opinion of the Court
OPINION
LUONGO, Chief Judge.
On or before December 14,1981, James T. Rideoutte, District Director of Internal Revenue for Philadelphia, made a termination assessment of federal income tax liability against plaintiff, John Berkery, pursuant to 26 U.S.C. § 6851(a)(1). 1 Plaintiff now brings this civil action pursuant to 26 U.S.C. § 7429 seeking judicial review and abatement of the termination assessment.
As gleaned from the pleadings, affidavits and testimony submitted by the parties, 2 the relevant facts are as follows. On December 11, 1981 Berkery was stopped by United States Customs officials…
2Cases cited6 opinions
- Loretto v. United StatesDistrict Court, E.D. Pennsylvania · 1977
- Haskin v. United StatesDistrict Court, C.D. California · 1977
- Isidoro M. Arana v. United States Immigration and Naturalization ServiceCourt of Appeals for the Third Circuit · 1982
- Fidelity Equipment Leasing Corp. v. United StatesDistrict Court, N.D. Georgia · 1978
- DeLauri v. United StatesDistrict Court, W.D. Texas · 1980
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Miller v. United StatesDistrict Court, N.D. Ohio · 1985
- Stebco, Inc. v. United StatesDistrict Court, S.D. California · 1990
- Hirschhorn v. United StatesDistrict Court, S.D. New York · 1987
- Vernon v. United StatesDistrict Court, M.D. North Carolina · 1984
- Rey Balaguer v. United StatesDistrict Court, D. Puerto Rico · 1987
2 more not listed; retrieve them via the Exa API.