Legal Opinion

Michaud v. United States

United States Court of Federal Claims

Decided November 26, 1997No. Nos. 92-822T, 92-823TPublishedCited by 11 opinions

1Opinion of the Court

OPINION

YOCK, Judge.

These consolidated tax refund cases are before the Court for decision after a trial on the merits, held in Milwaukee, Wisconsin, and in Washington, D.C. The plaintiffs seek recovery of payments that each remitted to the Internal Revenue Service (“IRS”) as partial payment of a 100 percent tax penalty assessed by the IRS against each of the plaintiffs pursuant to 26 U.S.C. (“I.R.C.”) § 6672 (1994). The defendant has counterclaimed for the unpaid balance of the penalty assessed against each plaintiff in these consolidated cases. The assessed penalties represent an…

2Cases cited27 opinions

  1. United States v. JanisSupreme Court of the United States · 1976
  2. Slodov v. United StatesSupreme Court of the United States · 1978
  3. Mazo v. United StatesCourt of Appeals for the Fifth Circuit · 1979
  4. Dudley J. Godfrey, Jr., Appellant/cross-Appellee v. United States, Appellee/cross-AppellantCourt of Appeals for the Federal Circuit · 1984
  5. Danville Plywood Corporation v. The United StatesCourt of Appeals for the Federal Circuit · 1990

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3Cited by11 opinions

  1. Cook v. United StatesUnited States Court of Federal Claims · 2000
  2. Dallin v. United StatesUnited States Court of Federal Claims · 2004
  3. Jenkins v. United StatesUnited States Court of Federal Claims · 2011
  4. Roger Byrne v. United StatesCourt of Appeals for the Sixth Circuit · 2017
  5. Farkas v. United StatesUnited States Court of Federal Claims · 2003

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