Legal Opinion
United States v. Shahadi
Court of Appeals for the Third Circuit
Decided January 8, 1965No. 14873PublishedCited by 7 opinions
1Opinion of the Court
STALEY, Circuit Judge.
This appeal requires us to decide whether under the Internal Revenue Code of 1939 the six-year statute of limitations on suits for collection based on jeopardy assessments is tolled while the determination of liability underlying the assessment is under consideration in the Tax Court. The district court found that the statute was suspended and that the proceeding for collection before it on complaint by the United States was therefore timely. The correctness of that decision is the only question before us on this appeal.
The operative facts were stipulated in the district…
2Cases cited7 opinions
- Albert N. Shahadi v. Commissioner of Internal Revenue, (Two Cases). Albert N. Shahadi, and Josephine Shahadi v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- American Equitable Assur. Co. of New York v. HelveringCourt of Appeals for the Second Circuit · 1933
- Shahadi v. CommissionerUnited States Tax Court · 1958
- Bartmer Automatic Self Service Laundry, Inc. v. CommissionerUnited States Tax Court · 1960
- Green Spring Dairy, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- United States v. Vera R. Maxwell, and Hugh Stanton Parker, Etc.Court of Appeals for the Fifth Circuit · 1972
- Principal Life Insurance v. United StatesUnited States Court of Federal Claims · 2010
- Martinez v. United States (In Re Martinez)United States Bankruptcy Court, E.D. Louisiana · 2007
- United States v. MaxwellDistrict Court, N.D. Texas · 1971
- United States v. ShahadiCourt of Appeals for the Third Circuit · 1965
2 more not listed; retrieve them via the Exa API.