Legal Opinion
Gagliardi v. United States
United States Court of Federal Claims
Decided May 16, 2008No. 06-799TPublishedCited by 4 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
CHRISTINE O.C. MILLER, Judge.
This tax refund suit is before the court following a two-day, five-witness trial. The Internal Revenue Service (the “IRS”) determined that the taxpayers understated their income for the 2000 and 2001 tax years. This understatement led to an assessment for underpayment of tax. The IRS attributed the underpayment to fraud and imposed a 75% fraud penalty for the 2000 and 2001 tax years pursuant to 26 U.S.C. (“I.R.C.”) § 6663(a) (2000). Plaintiffs sued for a refund of $17,742.75 in fraud penalties. Trial focused on whether the Government…
2Cases cited26 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Grace M. Powell, of the Estate of O. E. Powell, Deceased v. Ralph C. Granquist, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Joseph R. Dileo, Mary A. Dileo, Walter E. Mycek, Jr., Michele A. Mycek and Arcelo Reproduction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1992
- Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- William R. And Lorna E. Hall v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
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3Cited by4 opinions
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
- BONVILLAIN v. Louisiana Land & Exploration Co.District Court, E.D. Louisiana · 2010
- Minchem Int'l v. Comm'rUnited States Tax Court · 2015
- Dung T. Le & Nghia T. Tran v. CommissionerUnited States Tax Court · 2020