Legal Opinion

Griswold v. United States

Court of Appeals for the Eleventh Circuit

Decided August 4, 1995No. 94-2496PublishedCited by 39 opinions

1Opinion of the Court

BIRCH, Circuit Judge:

In this appeal, we decide the first impression issue of the requirements for the Internal Revenue Service (“IRS”) to release a federal tax lien pursuant to Internal Revenue Code (“I.R.C.”) § 6325, 1 and thereby avoid liability for damages pursuant to I.R.C. § 7432. 2 The district court found that, to release a federal tax lien, the IRS must file a certificate of release for each notice of federal tax lien filed against a taxpayer, original or refiled, but denied the taxpayer’s claim for damages because the IRS’s failure to file a certificate of release was neither knowing…

2Cases cited18 opinions

  1. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  2. Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
  3. Aquilino v. United StatesSupreme Court of the United States · 1960
  4. United States v. City of New BritainSupreme Court of the United States · 1954
  5. United States v. National Bank of CommerceSupreme Court of the United States · 1985

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

3Cited by39 opinions

  1. Fernandez v. CommissionerUnited States Tax Court · 2000
  2. Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
  3. Orville MacKlin v. United StatesCourt of Appeals for the Seventh Circuit · 2002
  4. Ginsburg v. Comm'rUnited States Tax Court · 2006
  5. Estate of Shelfer v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1996

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

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