Legal Opinion
United States v. Philadelphia Marine Trade Ass'n/International Longshoremen's Ass'n Vacation Fund
District Court, E.D. Pennsylvania
Decided January 11, 2007No. Civil Action 06-1071PublishedCited by 1 opinion
1Opinion of the Court
Memorandum and Order
GENE E.K. PRATTER, District Judge.
Philadelphia Marine Trade Association / International Longshoremen’s Association Vacation Fund (the “Fund”) has filed a Motion to Dismiss the United States of America’s Complaint pursuant to Federal Rules of Civil Procedure 12(b)(6) and 13(a) in this tax refund case brought pursuant to Section 7405 of the Internal Revenue Code (the “Code”), 26 U.S.C. § 7405. For the reasons discussed below, the Motion will be denied.
Factual and Prooedural Background
The United States originally filed this action in the District of New Jersey (the “New…
2Cases cited19 opinions
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- United States v. WurtsSupreme Court of the United States · 1938
- Transamerica Occidental Life Insurance Company v. Aviation Office of America, Inc. International Insurance CompanyCourt of Appeals for the Third Circuit · 2002
- Ransom v. MarrazzoCourt of Appeals for the Third Circuit · 1988
- Xerox Corp. v. SCM Corp.Court of Appeals for the Third Circuit · 1978
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3Cited by1 opinion
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