Legal Opinion

Adamowicz v. United States

Court of Appeals for the Second Circuit

Decided July 9, 2008No. Docket 06-4667-cv, 07-4723-cvPublishedCited by 14 opinions

1Per curiam

Petitioners-Appellants Michael Adamowicz and Elizabeth Fraser appeal from the decisions of the United States District Court for the Eastern District of New York (Wexler, J.) denying their petitions to quash four different third-party summonses and enforcing two other summonses issued by the Internal Revenue Service (“IRS”) as part of its ongoing investigation into the estate and gift tax liability of their mother’s estate. 1 Because we conclude that appellants have not met their burden of proof to show bad faith and improper purpose, and because we decide that technical violations occurring…

2Cases cited19 opinions

  1. United States v. PowellSupreme Court of the United States · 1964
  2. Grant Foster and Foster Construction C.A., Intervenors-Appellants v. United StatesCourt of Appeals for the Second Circuit · 1959
  3. United States of America and Ralph L. Guyette, Special Agent, Internal Revenue Service v. John B. HarringtonCourt of Appeals for the Second Circuit · 1968
  4. Tiffany Fine Arts, Inc. v. United StatesSupreme Court of the United States · 1985
  5. Equal Employment Opportunity Commission, Applicant-Appellee v. Quad/graphics, IncorporatedCourt of Appeals for the Seventh Circuit · 1995

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3Cited by14 opinions

  1. Jewell v. United StatesCourt of Appeals for the Tenth Circuit · 2014
  2. Jeffrey A. Azis v. United States Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 2013
  3. United States v. ClarkDistrict Court, D. Connecticut · 2008
  4. Highland Capital Management, L.P. v. United StatesCourt of Appeals for the Second Circuit · 2015
  5. United States v. BernhoftDistrict Court, E.D. Wisconsin · 2009

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

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