Legal Opinion

Stebco Inc. v. United States

Court of Appeals for the Ninth Circuit

Decided October 11, 1990No. 90-55780PublishedCited by 18 opinions

1Opinion of the Court

AMENDED ORDER

Taxpayers Rafael Carrillo-Barron and Norma Fregoso Carrillo (“the Carrillos”) bring this motion to dismiss the govern-*687merit’s appeal from the district court’s order denying the government’s motion to dismiss for lack of venue. Taxpayers also request attorneys’ fees pursuant to 26 U.S.C. § 7430. Appellees’ motion to dismiss is granted, and the request for attorneys’ fees is denied.

This case arises out of jeopardy assessments made against the Carrillos by the IRS pursuant to 26 U.S.C. § 6861,1 which permits the IRS to assess and collect a tax deficiency immediately if the IRS…

2Cases cited5 opinions

  1. Donald E. Hiley and Ruth v. Hiley v. United StatesCourt of Appeals for the Seventh Circuit · 1986
  2. Norma Williams v. United StatesCourt of Appeals for the Eleventh Circuit · 1983
  3. Carlos Zuluaga v. United StatesCourt of Appeals for the Ninth Circuit · 1985
  4. Linda Marie Nichols v. United StatesCourt of Appeals for the Ninth Circuit · 1980
  5. Richard L. Meadows v. United StatesCourt of Appeals for the Eleventh Circuit · 1982

3Cited by18 opinions

  1. Rosario Gutierrez v. Jo Anne Barnhart, Commissioner, Social Security AdministrationCourt of Appeals for the Ninth Circuit · 2001
  2. Nalle v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
  3. Maria Medina Tovar v. Laura ZuchowskiCourt of Appeals for the Ninth Circuit · 2022
  4. Tkb International, Inc. v. United States of America, Tkb International, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1993
  5. Nalle v. CommissionerUnited States Tax Court · 1994

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