Legal Opinion
United States of America and Dennis J. Hanzel, Special Agent, Internal Revenue Service v. Jay T. Will
Court of Appeals for the Sixth Circuit
Decided February 24, 1982No. 80-3680PublishedCited by 82 opinions
1Opinion of the Court
NATHANIEL R. JONES, Circuit Judge.
Appellant Jay T. Will appeals from the district court’s order granting enforcement of an Internal Revenue Service (IRS) summons. Appellant contends that the summons was issued in bad faith and for purposes of harassment. He also urges that the district court erred in limiting his attempt to prove this fact. For the reasons stated below, we affirm the district court’s decision.
During the spring of 1978, Dennis J. Hanzel, a special agent of the IRS, learned that Jay T. Will (hereinafter taxpayer) was accumulating numerous assets. After examining a number of the…
2Cases cited10 opinions
- United States v. PowellSupreme Court of the United States · 1964
- Donaldson v. United StatesSupreme Court of the United States · 1971
- United States v. LaSalle National BankSupreme Court of the United States · 1978
- United States v. McCarthyCourt of Appeals for the Third Circuit · 1975
- Thelma Rosenberg v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
5 more not listed; retrieve them via the Exa API.
3Cited by82 opinions
- Pierre Boulez v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- In Re EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, PetitionerCourt of Appeals for the Fifth Circuit · 1983
- Wayne R. La Mura v. United StatesCourt of Appeals for the Eleventh Circuit · 1985
- United States v. Ronald P. MarkwoodCourt of Appeals for the Sixth Circuit · 1995
77 more not listed; retrieve them via the Exa API.