Legal Opinion
Cooper v. United States
District Court, D. New Jersey
Decided February 4, 1993No. Civ. A. 91-1009(JCL)PublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM AND ORDER
LIFLAND, District Judge.
This matter comes before the Court on cross-motions for summary judgment by plaintiffs Sandra Cooper and Larry Cooper (“plaintiffs”) and by defendant United States of America (“United States”). Plaintiffs commenced the instant action seeking a refund of late filing penalties and late payment penalties assessed by the Internal Revenue Service (“IRS”) and paid by plaintiffs concerning the tax years 1982 through 1986.
BACKGROUND
The relevant facts are not in dispute. In 1982, plaintiff Larry Cooper became the subject of a criminal investigation by the…
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. BoyleSupreme Court of the United States · 1985
- United States v. SullivanSupreme Court of the United States · 1927
- Garner v. United StatesSupreme Court of the United States · 1976
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
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3Cited by3 opinions
- Pransky v. Internal Revenue Service (In Re Pransky)United States Bankruptcy Court, D. New Jersey · 1999
- Cooper (Larry, Sandra) v. United StatesCourt of Appeals for the Third Circuit · 1993
- Geddis v. Comm'rUnited States Tax Court · 2005