Legal Opinion
Beall v. United States
Court of Appeals for the Fifth Circuit
Decided October 11, 2006No. 04-41594PublishedCited by 9 opinions
1Opinion of the Court
OWEN, Circuit Judge:
Taxpayers are seeking abatement of interest pursuant to 26 U.S.C. § 6404(e), asserting that delays and errors by the Internal Revenue Service constituted ministerial acts within the meaning of section 6404(e) and resulted in the impairment of the taxpayers’ ability to defend against adjustments to partnership items that caused additional tax liability, penalty and interest for the individual taxpayers. The district court granted the United States’ Rule 12(b)(6) 1 motion to dismiss for failure to state a claim. Because none of the errors or delays of which the taxpayers…
2Cases cited7 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Horton v. CaliforniaSupreme Court of the United States · 1990
- Raymond W. Beall Hazel A. Beall v. United StatesCourt of Appeals for the Fifth Circuit · 2003
- United States ex rel. American Bank v. C.I.T. Construction Inc. of TexasCourt of Appeals for the Fifth Circuit · 1991
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Huffman v. Union Pacific RailroadCourt of Appeals for the Fifth Circuit · 2012
- Intellivision v. Microsoft Corp.District Court, S.D. New York · 2011
- Ford-Evans v. United Space Alliance LLCCourt of Appeals for the Fifth Circuit · 2009
- Thai Plastic Bags Industries Co. v. United StatesUnited States Court of International Trade · 2010
- Abel M. Siller, and Enriqueta Siller, Mario M. Siller, Angelina Siller, Santiago Siller, and Virginia Siller (Appellant/Cross Appellee) v. LPP Mortgage, LTD (Appellee/Cross Appellant), Texas Court of Appeals, 4th District (San Antonio)2013
4 more not listed; retrieve them via the Exa API.