Legal Opinion

K.A. Morris v. United States of America, the Department of the Treasury, Internal Revenue Service

Court of Appeals for the Eleventh Circuit

Decided March 27, 1987No. 86-3514PublishedCited by 35 opinions

1Opinion of the Court

TUTTLE, Senior Circuit Judge:

This is an appeal from a district court judgment, 652 F.Supp. 120, which dismissed the plaintiff’s suit under the Internal Revenue Code Section 7426, providing for an action to be filed by a person who claims that his property has been improperly levied upon for the taxes due by a different taxpayer. 1

This non-jury trial began with the trial court addressing the plaintiff: “All right, sir. Call your first witness.”

To this statement, Mr. Boda, plaintiff’s counsel answered: “Your Honor, as I understand it, because of the nature of this action, the government is…

2Cases cited8 opinions

  1. Diaz v. United StatesSupreme Court of the United States · 1912
  2. Spiller v. Atchison, Topeka & Santa Fe Railway Co.Supreme Court of the United States · 1920
  3. Valley Finance, Inc. v. United StatesCourt of Appeals for the D.C. Circuit · 1980
  4. Damon v. CarrolMassachusetts Supreme Judicial Court · 1895
  5. Manuel Flores and Wilshire Insurance Company, Appellants-Cross-Appellees v. United States of America, Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 1977

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3Cited by35 opinions

  1. Edith Libutti, Doing Business as Lion Crest Stable, a Sole Proprietorship v. United StatesCourt of Appeals for the Second Circuit · 1997
  2. Century Hotels, Crismar Corporation, Movant-Appellant v. United StatesCourt of Appeals for the Fifth Circuit · 1992
  3. Earl Winebrenner v. United StatesCourt of Appeals for the Ninth Circuit · 1991
  4. Glenda S. Scoville v. United StatesCourt of Appeals for the Eighth Circuit · 2001
  5. United States v. Herberto PulgarCourt of Appeals for the Seventh Circuit · 2015

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

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