Legal Opinion
Fleming v. United States
District Court, E.D. Wisconsin
Decided January 30, 1980No. 79-C-34PublishedCited by 6 opinions
1Opinion of the Court
MEMORANDUM AND ORDER
WARREN, District Judge.
This is a civil action brought pursuant to 28 U.S.C. § 1346(a)(1). Plaintiff seeks return of $28,688.63 additional estate tax assessed following plaintiff’s failure to file the estate tax return and the estate tax by. the due date. 26 U.S.C. § 6651(a)(1). Plaintiff has moved for summary judgment in his behalf, arguing that he should be excused from the penalty because his “failure [to timely file was] due to reasonable cause and not due to willful neglect . . .” 26 U.S.C. § 6651(a)(1).
Defendant seeks summary judgment for the amount of the additional…
2Cases cited10 opinions
- Poller v. Columbia Broadcasting System, Inc.Supreme Court of the United States · 1962
- Spies v. United StatesSupreme Court of the United States · 1943
- Heman v. CommissionerUnited States Tax Court · 1959
- United States v. Richard L. Kroll, of the Estate of Gertrude O'reilly, DeceasedCourt of Appeals for the Seventh Circuit · 1977
- Ferrando v. United StatesCourt of Appeals for the Ninth Circuit · 1957
5 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- John B. Fleming, Personal Representative of the Estate of John J. Fleming, Deceased v. United StatesCourt of Appeals for the Seventh Circuit · 1981
- Armstrong's, Inc. v. Iowa Department of RevenueSupreme Court of Iowa · 1982
- Atlantic Bottling Co. v. Iowa Department of RevenueSupreme Court of Iowa · 1986
- Twin City Const. Co. of Fargo v. United StatesDistrict Court, D. North Dakota · 1981
- Armstrong's, Inc. v. Iowa Department of RevenueSupreme Court of Iowa · 1982
1 more not listed; retrieve them via the Exa API.