Legal Opinion
Gerald J. Rapp and Mary H. Rapp v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided October 18, 1985No. 84-7490PublishedCited by 87 opinions
1Opinion of the Court
CANBY, Circuit Judge:
Gerald and Mary Rapp appeal a decision of the Tax Court granting the Commissioner’s motion for summary judgment on the Rapps’ petition for redetermination of tax deficiencies and additions to tax, and denying their motion to suppress notices of deficiency and certificates of assessment. We affirm.
A. Motion to Suppress
The IRS, pursuant to 26 U.S.C. § 7602, is authorized to examine' records and issue summonses for the purpose of determining the tax liability of any individual. When an IRS summons is served on a “third-party record keeper,” the taxpayer to whom the records…
2Cases cited21 opinions
- Hoffman Estates v. Flipside, Hoffman Estates, Inc.Supreme Court of the United States · 1982
- United States v. MillerSupreme Court of the United States · 1976
- Grosshandler v. CommissionerUnited States Tax Court · 1980
- Albertson v. Subversive Activities Control BoardSupreme Court of the United States · 1966
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
16 more not listed; retrieve them via the Exa API.
3Cited by87 opinions
- Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Norman D. Carter and Cecilia P. Carter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Joseph Edelson and Harriet Edelson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Cathy Miller Hardy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- David C. Enrici Marianne Enrici Lawrence H. Easterling Phyllis Easterling v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
82 more not listed; retrieve them via the Exa API.