Legal Opinion

Martin Alpert and Carolyn Alpert v. United States

Court of Appeals for the Sixth Circuit

Decided March 23, 2007No. 06-3415PublishedCited by 95 opinions

1Opinion of the Court

GIBBONS, Circuit Judge.

Appellants Martin and Carolyn Alpert appeal the district court’s grant of summary judgment to appellee United States because the Alperts failed to present evidence of an essential element of their claim for refund of overpaid taxes. The Alperts argue that they have presented sufficient evidence to create a disputed issue of material fact as to when the debts of their wholly-owned subchapter S corporation were discharged in bankruptcy. For the reasons stated below, we affirm the decision of the district court.

I

During the years at issue, the Alperts were a married couple…

2Cases cited8 opinions

  1. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  2. Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
  3. U.S. Structures, Incorporated, a Foreign Corporation v. J.P. Structures, Incorporated, a Michigan Corporation, and Joseph J. PilatCourt of Appeals for the Sixth Circuit · 1997
  4. Gitlitz v. CommissionerSupreme Court of the United States · 2001
  5. Kalamazoo Acquisitions, L.L.C. v. Westfield Insurance Co., Inc.Court of Appeals for the Sixth Circuit · 2005

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3Cited by95 opinions

  1. Alexander v. CareSourceCourt of Appeals for the Sixth Circuit · 2009
  2. Steven Ondo v. City of ClevelandCourt of Appeals for the Sixth Circuit · 2015
  3. Shazor v. Professional Transit Management, Ltd.Court of Appeals for the Sixth Circuit · 2014
  4. Livingston Christian Schools v. Genoa Charter TownshipCourt of Appeals for the Sixth Circuit · 2017
  5. Magnum Towing & Recovery v. City of ToledoCourt of Appeals for the Sixth Circuit · 2008

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