Legal Opinion
Payne v. United States
District Court, D. Vermont
Decided November 21, 1991No. 89-110PublishedCited by 2 opinions
1Opinion of the Court
COFFRIN, Senior District Judge.
In 1986, the Internal Revenue Service levied on Payne’s bank accounts in partial satisfaction of unpaid 1982 federal income taxes. Payne commenced this action to recover the seized funds, and the Internal Revenue Service counterclaimed to reduce the assessment to judgment and moved for summary judgment. We find Payne’s 1982 income was not exempt from federal income taxation and grant the government’s summary judgment motion.
BACKGROUND
In 1982, taxpayer Payne’s late husband earned $75,780.00 while working for the Panama Canal Commission (“PCC”) in the Republic of…
2Cases cited27 opinions
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Joseph E. Dister v. The Continental Group, Inc.Court of Appeals for the Second Circuit · 1988
- Standard Oil Co. of Cal. v. JohnsonSupreme Court of the United States · 1942
- United States v. MitchellSupreme Court of the United States · 1926
- United States v. Wells Fargo BankSupreme Court of the United States · 1988
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3Cited by2 opinions
- In Re BardenDistrict Court, E.D. New York · 1996
- A. Joyce Payne v. United StatesCourt of Appeals for the Second Circuit · 1992