Griswold v. United States
Court of Appeals for the Eleventh Circuit
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
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- Aquilino v. United StatesSupreme Court of the United States · 1960
- United States v. City of New BritainSupreme Court of the United States · 1954
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
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3Cited by39 opinions
- Fernandez v. CommissionerUnited States Tax Court · 2000
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Orville MacKlin v. United StatesCourt of Appeals for the Seventh Circuit · 2002
- Ginsburg v. Comm'rUnited States Tax Court · 2006
- 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.