Legal Opinion

Roat v. Commissioner

Court of Appeals for the Ninth Circuit

Decided May 27, 1988No. Nos. 86-3857, 86-7479, 86-7480, 86-7482, 86-7483, 86-7487 and 87-1559PublishedCited by 61 opinions

1Opinion of the Court

BEEZER, Circuit Judge:

Appellants did not file income tax returns. They challenge their income tax on the theory that the Commissioner cannot determine their tax deficiencies until he prepares returns on their behalf. The Tax Court denied five appellants’ motions to dismiss for lack of jurisdiction, and granted the Commissioner’s motions for failure to prosecute. The district courts denied in-junctive relief to two other appellants as barred by the Anti-Injunction Act. We affirm, except that we dismiss as to appellant Roat and remand, for a limited purpose, as to appellant Moore.

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2Cases cited14 opinions

  1. Helvering v. TaylorSupreme Court of the United States · 1935
  2. Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
  3. Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
  4. Commissioner v. ShapiroSupreme Court of the United States · 1976
  5. Michael R. Wood, Individually and Dba National Photo Services v. Willard W. McEwen Jr.Court of Appeals for the Ninth Circuit · 1981

9 more not listed; retrieve them via the Exa API.

3Cited by61 opinions

  1. United States v. Roy W. CollinsCourt of Appeals for the Tenth Circuit · 1990
  2. Wnuck v. CommissionerUnited States Tax Court · 2011
  3. Charles A. Roat v. Commissioner, Internal Revenue Service Alaska USA Federal Credit Union Felec Services, Inc., Robert J. Haggerty v. Commissioner, Internal Revenue Service, Douglas G. Wade v. Commissioner, Internal Revenue Service, H. Milton Moore v. Commissioner, Internal Revenue Service, Erby D. Brown v. Commissioner, Internal Revenue Service, John M. Shorter v. Commissioner, Internal Revenue Service, Manuel C. Borbon v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
  4. Hawkins v. Comm'rUnited States Tax Court · 2008
  5. Pearce v. CommissionerUnited States Tax Court · 1990

56 more not listed; retrieve them via the Exa API.

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