Legal Opinion
First National Bank in Palm Beach, of the Will of Frederick S. Holmes v. United States of America, J. W. Perry, Third-Party
Court of Appeals for the First Circuit
Decided March 23, 1979No. 76-3309PublishedCited by 29 opinions
1Opinion of the Court
ALVIN B. RUBIN, Circuit Judge:
The primary question presented by this appeal is whether the IRS is required to apply partial deposits made because of liability for withholding taxes by an employer corporation, Armstrong Building Corporation, but without description of the debt to which they are to apply, solely to the corporation’s outstanding withholding liability rather than to penalties and interest later assessed.
First National Bank in Palm Beach and J. W. Perry appeal from a judgment entered by the district court dismissing, with prejudice, FNB’s suit for refund of a $10,831.60 penalty…
2Cases cited18 opinions
- Slodov v. United StatesSupreme Court of the United States · 1978
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Tayloe v. T. & S. SandifordSupreme Court of the United States · 1822
- Wallace L. Sorenson v. United StatesCourt of Appeals for the Ninth Circuit · 1975
- Pacific National Insurance Company v. United StatesCourt of Appeals for the Ninth Circuit · 1970
13 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Commonwealth National Bank of Dallas, Cross v. United States of America, CrossCourt of Appeals for the Fifth Circuit · 1982
- Bankr. L. Rep. P 75,404 in Re Fred J. Wines, Debtor. Fred J. Wines v. Marian A. WinesCourt of Appeals for the Eleventh Circuit · 1993
- Albert A. Stevens v. United States of America, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1995
- United States v. Security Pacific Business Credit, Inc.Court of Appeals for the Seventh Circuit · 1992
- Jenkins v. United StatesUnited States Court of Federal Claims · 2011
24 more not listed; retrieve them via the Exa API.