Legal Opinion
United States v. Geniviva
Court of Appeals for the Third Circuit
Decided February 7, 1994No. 93-3254PublishedCited by 16 opinions
1Opinion of the Court
OPINION OF THE COURT
NYGAARD, Circuit Judge.
Brian and Marilyn Geniviva appeal from an order of the district court granting summary judgment to the United States in its action to impose transferee liability against them for unpaid taxes due from the estate of Helen Geniviva. The district court held that the suit was not time-barred, even though no assessment was filed under 26 U.S.C. § 6901 and the time for doing so had passed. Because a section 6901 assessment is not a prerequisite to an action against transferees under 26 U.S.C. § 6324(a)(2) and this case was filed within the statutory period…
2Cases cited5 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Leighton v. United StatesSupreme Court of the United States · 1933
- United States v. Harriett C. Russell, of the Estate of T. C. Russell, DeceasedCourt of Appeals for the Tenth Circuit · 1972
- United States v. DeGroftDistrict Court, D. Maryland · 1981
- United States v. RussellUnited States District Court for the District of Arkansas · 1971
3Cited by16 opinions
- Hillen v. City of Many Trees (In re CVAH, Inc.)United States Bankruptcy Court, D. Idaho · 2017
- Estate of Woll ex rel. Woll v. United StatesCourt of Appeals for the Seventh Circuit · 1994
- United States v. PerrinaDistrict Court, D. New Jersey · 1994
- United States v. GenivivaCourt of Appeals for the Third Circuit · 1994
- United States v. Estate of DavenportDistrict Court, N.D. Oklahoma · 2001
11 more not listed; retrieve them via the Exa API.