Legal Opinion

Nix v. United States

District Court, E.D. Texas

Decided September 6, 2018No. CASE NO. 2:17-CV-00434; CASE NO. 2:17-CV-00435; CASE NO. 2:17-CV-00436PublishedCited by 1 opinion

1Opinion of the Court

RODNEY GILSTRAP, UNITED STATES DISTRICT JUDGE

On April 12, 2018, this Court issued a summary order that GRANTED Defendant's Motion to Dismiss Plaintiff's Section 6751 Claims. (Dkt. No. 115.) In that order, the Court announced its intention to issue a written opinion providing "a full explanation and analysis of the Court's ruling announced into the record." (Id. at 2.) Such explanation and analysis is provided herein.

I. BACKGROUND

This is a partner-level refund suit filed under 26 U.S.C. § 6230(c)(3) after three partners, Harold Nix ("Nix"), Charles Patterson ("Patterson"), and Nelson Roach…

2Cases cited14 opinions

  1. Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
  2. United States v. WoodsSupreme Court of the United States · 2013
  3. Chai v. CommissionerCourt of Appeals for the Second Circuit · 2017
  4. Elizabeth N. Callaway v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
  5. Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009

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3Cited by1 opinion

  1. Alan H. Ginsburg v. United StatesCourt of Appeals for the Eleventh Circuit · 2021

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