Legal Opinion
Louis J. Capozzoli, Jr. And Laura B. Capozzoli v. W. J. Tracey, Jr.
Court of Appeals for the Fifth Circuit
Decided December 11, 1981No. 81-3017PublishedCited by 65 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
Louis and Laura Capozzoli brought this suit under the Federal Tort Claims Act, 28 U.S.C. § 2671 et seq. (“FTCA”), for damages based on the allegedly tortious conduct of an agent of the Internal Revenue Service (“IRS”). The District Court dismissed the action on the grounds that it was barred by 28 U.S.C. § 2680(c), an exception to the FTCA which retains the government’s sovereign immunity for “[a]ny claims arising in respect of the assessment or collection of any tax....” We affirm.
PRELUDE
In 1979, William Tracey was employed by the IRS as an Engineer Revenue Agent. His…
2Cases cited9 opinions
- Bivens v. Six Unknown Named Agents of Federal Bureau of NarcoticsSupreme Court of the United States · 1971
- Bob Jones University v. SimonSupreme Court of the United States · 1974
- James B. Stanley v. Central Intelligence Agency United States Department of Defense U.S. ArmyCourt of Appeals for the Fifth Circuit · 1981
- Melvin Morris, Jr., and Ramona Morris v. United States of AmericaCourt of Appeals for the Ninth Circuit · 1975
- American Association of Commodity Traders v. Department of the Treasury, Internal Revenue Service and United States of AmericaCourt of Appeals for the First Circuit · 1979
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3Cited by65 opinions
- Susie Myers Perkins, Administratrix of the Estate of John David Perkins, Jr., Deceased v. United StatesCourt of Appeals for the Fourth Circuit · 1995
- National Commodity & Barter Ass'n, National Commodity Exchange v. GibbsCourt of Appeals for the Tenth Circuit · 1989
- Jose Aguado Cervantes v. United StatesCourt of Appeals for the Ninth Circuit · 2003
- John B. Cameron, Jr. v. Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1985
- Snyder & Associates Acquisitions LLC v. United StatesCourt of Appeals for the Ninth Circuit · 2017
60 more not listed; retrieve them via the Exa API.