Legal Opinion
Bruce Perlowin v. Michael D. Sassi, District Director of Internal Revenue, San Francisco, California, and United States of America
Court of Appeals for the Ninth Circuit
Decided July 29, 1983No. 82-4530PublishedCited by 31 opinions
1Per curiam
Taxpayer brought this action seeking to have a termination assessment decision declared invalid and to have the Internal Revenue Service enjoined from enforcing the assessment. The district court declared the assessment invalid, restrained the IRS from attempting any further collections pursuant to the assessment and ordered return of all seized assets. Perlowin v. Sassi, 544 F.Supp. 89 (N.D.Cal.1982).
The relevant facts are set out in the district court’s opinion. We hold that the district court correctly interpreted the statutes. The court failed, however, to apply the equity standards for…
2Cases cited7 opinions
- Simon v. Eastern Kentucky Welfare Rights OrganizationSupreme Court of the United States · 1976
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- Laing v. United StatesSupreme Court of the United States · 1976
- Eastern Kentucky Welfare Rights Organization v. William E. Simon, Secretary of the TreasuryCourt of Appeals for the D.C. Circuit · 1974
- Philadelphia & Reading Corp. v. BeckCourt of Appeals for the Seventh Circuit · 1982
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3Cited by31 opinions
- Cohen v. United StatesCourt of Appeals for the D.C. Circuit · 2011
- Conrad Keado v. United States of America, Conrad L. Keado and Linda W. Keado v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- In Re Leckie Smokeless Coal Company New River Mineral Resources Company Gould Resources, Incorporated, Debtors (Two Cases). United Mine Workers of America 1992 Benefit Plan, and Its Trustees United Mine Workers of America Combined Benefit Fund, and Its Trustees, Movants-Appellants v. Leckie Smokeless Coal Company New River Mineral Resources Company Gould Resources, Incorporated Royal Scot Minerals, Incorporated, and Unsecured Creditors Committee Office of the United States Trustee, Parties-In-Interest. United Mine Workers of America 1992 Benefit Plan, and Its Trustees United Mine Workers of America Combined Benefit Fund, and Its Trustees, Movants-Appellants v. Leckie Smokeless Coal Company New River Mineral Resources Company Gould Resources, Incorporated Royal Scot Minerals, Incorporated, and Unsecured Creditors Committee United States Trustee, Parties-In-Interest. In Re Lady H Coal Company, Incorporated Consolidated Sewell, Incorporated Sewell Coal Company Leivasy Mining Corporation Eastwood Construction, Incorporated, Debtors (Two Cases). Lady H Coal Company, Incorporated Consolidated Sewell, Incorporated Sewell Coal Company Leivasy Mining Corporation Eastwood Construction, Incorporated, Debtors-Appellees v. United Mine Workers of America 1992 Benefit Plan, and Its Trustees, Movant-Appellant, and United Mine Workers of America Combined Benefit Fund, and Its Trustees, Movant, and International Union, United Mine Workers of America District 17, United Mine Workers of America, Parties-In-Interest. Lady H Coal Company, Incorporated Consolidated Sewell, Incorporated Leivasy Mining Corporation Eastwood Construction, Incorporated, Debtors-Appellees v. United Mine Workers of America 1992 Benefit Plan, and Its Trustees, Movant-Appellant, and International Union, United Mine Workers of America District 17, United Mine Workers of America, Parties-In-InterestCourt of Appeals for the Fourth Circuit · 1996
- Flynn, M. Rutledge v. United States of America by and Through Eggers, Roscoe Commissioner of Internal Revenue. Appeal of M. Rutledge FlynnCourt of Appeals for the Third Circuit · 1986
- Rodriguez v. United StatesDistrict Court, N.D. Illinois · 1986
26 more not listed; retrieve them via the Exa API.