Legal Opinion

Milazzo v. United States

District Court, S.D. California

Decided January 16, 1984No. Civ. 83-1901-T, 83-1936-T, 83-1980-T and 83-2016-TPublishedCited by 20 opinions

1Opinion of the Court

ORDER

TURRENTINE, Chief Judge.

The plaintiffs in these actions filed what purport to be their income tax returns for 1982, refusing to furnish any financial data on the forms on the basis of their constitutional rights against self-incrimination. The Internal Revenue Service (“IRS”) determined in each case that the purported tax return could not be processed and that it constituted a “frivolous” return within the meaning of § 6702 of the Internal Revenue Code (“Code”) of 1954 (26 U.S.C.), which was added to the Code by § 326(a) of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA),…

2Cases cited23 opinions

  1. Hoffman v. United StatesSupreme Court of the United States · 1951
  2. Helvering v. MitchellSupreme Court of the United States · 1938
  3. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  4. Phillips v. CommissionerSupreme Court of the United States · 1931
  5. Bob Jones University v. SimonSupreme Court of the United States · 1974

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3Cited by20 opinions

  1. Kahn, Emily v. United StatesCourt of Appeals for the Third Circuit · 1985
  2. Ralph E. Heitman v. United StatesCourt of Appeals for the Sixth Circuit · 1984
  3. Steven R. Wardell v. United StatesCourt of Appeals for the Eighth Circuit · 1985
  4. Texas Association of Concerned Taxpayers, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1985
  5. Boday v. United StatesCourt of Appeals for the Ninth Circuit · 1985

15 more not listed; retrieve them via the Exa API.

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