Legal Opinion
Allan v. United States
District Court, N.D. Texas
Decided January 6, 1975No. Civ. A. 3-6083-FPublishedCited by 11 opinions
1Opinion of the Court
MEMORANDUM OPINION
ROBERT W. PORTER, District Judge.
This is a suit for the refund of some $20,000 assessed as a 100 percent penalty under § 6672 of the Internal Revenue Code of 1954 (26 U.S.C. § 6672). The taxpayer-plaintiff argues that he is not liable for the tax because the Internal Revenue Service made a clerical error on certain forms it mailed him, which incorrectly stated the name of the corporation that had failed to pay over withholding and social security taxes.
Both parties have filed motions for summary judgment. I have concluded that the government’s motion must be granted, and the…
2Cases cited6 opinions
- Robert White v. The United StatesUnited States Court of Claims · 1967
- Carolyn Brafman v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- In Re SerigneseDistrict Court, D. Connecticut · 1963
- United States v. LehighDistrict Court, W.D. Arkansas · 1961
- Stephanie Bauer v. John E. Foley, as District Director of Internal Revenue Service, Buffalo District, and the United StatesCourt of Appeals for the Second Circuit · 1968
1 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- John A. Sage v. United StatesCourt of Appeals for the Fifth Circuit · 1990
- Planned Investments, Inc., Michigan Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1989
- Matter of SaxeUnited States Bankruptcy Court, S.D. New York · 1981
- Livingstone v. Department of TreasuryMichigan Supreme Court · 1990
- Houston v. United StatesDistrict Court, W.D. Michigan · 1988
6 more not listed; retrieve them via the Exa API.