Legal Opinion
McNichols v. Commissioner
Court of Appeals for the First Circuit
Decided December 29, 1993No. 93-1622PublishedCited by 28 opinions
1Opinion of the Court
BOWNES, Senior Circuit Judge.
This is an appeal from a decision of the tax court holding the petitioner civilly hable for deficiencies in income tax for the years 1981 and 1982. The tax court also found petitioner hable for additions to the tax due. The amounts are substantial, but the computations are not contested. The tax court brushed aside petitioner’s main defense, that imposition of the deficiencies and additions to tax violates the proscription against excessive fines of the Eighth Amendment and violates the Double Jeopardy protection against multiple punishments under the Fifth…
2Cases cited9 opinions
- United States v. HalperSupreme Court of the United States · 1989
- Austin v. United StatesSupreme Court of the United States · 1993
- Helvering v. MitchellSupreme Court of the United States · 1938
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- James v. United StatesSupreme Court of the United States · 1961
4 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Paul L. Thomas v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995
- William D. Little v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1997
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
- United States v. TothCourt of Appeals for the First Circuit · 2022
- Dewees v. United StatesDistrict Court, District of Columbia · 2017
23 more not listed; retrieve them via the Exa API.