Legal Opinion

Conway v. United States

District Court, D. Maryland

Decided August 10, 1995No. Civ. A. No. MJG-93-1707PublishedCited by 4 opinions

1Opinion of the Court

MEMORANDUM AND ORDER

GARBIS, District Judge.

The Court has before it the United States’ Motion for Summary Judgment, United States’ [Second] Motion for Summary Judgment, Plaintiffs’ Motion for Summary Judgment and the materials submitted by the parties relating thereto. The Court has held a hearing and had the benefit of the arguments of counsel.

The Court recognizes that Mr. and Mrs. Conway (“the Taxpayers”) acted in good faith and without intent to evade their tax responsibilities. Nevertheless, the Court concludes that, in view of the undisputed facts and the pertinent provisions of the…

2Cases cited5 opinions

  1. Maryland State Teachers Ass'n v. HughesDistrict Court, D. Maryland · 1984
  2. City of Frederick v. QuinnCourt of Special Appeals of Maryland · 1977
  3. Baker v. Baltimore County, Md.District Court, D. Maryland · 1980
  4. Roy G. Edwards and Deborah S. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1990
  5. Wheeler v. CommissionerUnited States Tax Court · 1993

3Cited by4 opinions

  1. Allan R. Powell Joan K. Powell v. Commissioner of Internal Revenue, Richard J. Montgomery Adele S. Montgomery v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1997
  2. Brown v. CommissionerUnited States Tax Court · 1996
  3. Powell v. CommissionerCourt of Appeals for the Fourth Circuit · 1997
  4. Thompson v. CommissionerUnited States Tax Court · 1996

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