Legal Opinion

Engh v. United States

District Court, N.D. Illinois

Decided April 20, 1987No. 86C6376PublishedCited by 4 opinions

1Opinion of the Court

MEMORANDUM OPINION AND ORDER

SHADUR, District Judge.

Herbert and Carol Engh (“Enghs”) have sued the United States (“Government”) under 26 U.S.C. § 7422, 1 seeking a refund of federal income tax deficiencies, interest and penalties assessed by and paid to the Internal Revenue Service (“IRS”) for calendar years 1979 (Count I), 1980 (Count II) and 1982 (Count III). 2 Government has moved under Fed.R.Civ.P. (“Rule”) 56 for summary judgment on Counts I and III, together with costs, attorneys’ fees and other sanctions under Rule 11. For the reasons stated in this memorandum opinion and order,…

2Cases cited20 opinions

  1. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  2. Fuentes v. ShevinSupreme Court of the United States · 1972
  3. Montana v. United StatesSupreme Court of the United States · 1979
  4. Mitchell v. W. T. Grant Co.Supreme Court of the United States · 1974
  5. Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986

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3Cited by4 opinions

  1. Napier v. Thirty or More Unidentified Federal Agents, Employees or OfficersCourt of Appeals for the Third Circuit · 1988
  2. Napier v. Thirty or More Unidentified Federal Agents, Employees or OfficersCourt of Appeals for the Third Circuit · 1988
  3. Purk v. United StatesDistrict Court, S.D. Ohio · 1989
  4. Diversified Technologies Corp. v. Jerome Technologies, Inc.District Court, N.D. Illinois · 1988

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