Baccei v. United States
Court of Appeals for the Ninth Circuit
1Opinion of the Court
OPINION
BURGESS, District Judge:
I
Ronald B. Baccei, Trustee of the Eda 0. Pucci 2004 Revocable Trust, initiated this action in the Northern District of California, seeking a refund of a penalty imposed by the Internal Revenue Service for late payment of an estate tax. Baccei appeals the district court’s summary judgment order, arguing that the district court erred in: (1) concluding the substantial compliance doctrine was inapplicable to regulations governing payment extension requests; (2) finding the IRS was not equitably estopped from assessing the late payment penalty and interest; and (3)…
2Cases cited19 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- W. Michael Kimes J. Colette Boykin v. Peter G. Stone, Judge, Superior Court Robert L. Mezzetti, II Henry Mariani Robert MacHadoCourt of Appeals for the Ninth Circuit · 1996
- Sergeant Perry Watkins v. United States ArmyCourt of Appeals for the Ninth Circuit · 1989
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- In Re: America West Airlines, Inc., Debtor. El Paso City of Texas v. America West Airlines, Inc.Court of Appeals for the Ninth Circuit · 2000
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- Cruz Ex Rel. Cruz v. International Collection Corp.Court of Appeals for the Ninth Circuit · 2012
- City of Philadelphia v. SessionsDistrict Court, E.D. Pennsylvania · 2017
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