Legal Opinion

Gattuso v. Pecorella

Court of Appeals for the Ninth Circuit

Decided May 22, 1984No. 83-2462PublishedCited by 26 opinions

1Per curiam

Taxpayers sued the Internal Revenue Service and various officers seeking an “abatement of the finding” that they owed taxes for the years 1980, 1981, and 1982. They contend their wages are not “income” within the meaning of the Internal Revenue Code.

The government moved to dismiss on the grounds that the district court lacked jurisdiction and the taxpayers failed to state a claim upon which relief could be granted. The district court granted this motion.

The district court clearly lacked jurisdiction to “abate the findings” that taxpayers had taxable income for the years in question. The…

2Cases cited9 opinions

  1. Flora v. United StatesSupreme Court of the United States · 1960
  2. William H. And Avilda L. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
  3. United States of America, Gary O. Booth, Richard D. Roller, and Barbara A. Shandony v. Douglas M. HartCourt of Appeals for the Eighth Circuit · 1983
  4. Taylor v. Sentry Life Insurance CompanyCourt of Appeals for the Ninth Circuit · 1984
  5. United States v. Robert R. RomeroCourt of Appeals for the Ninth Circuit · 1981

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

3Cited by26 opinions

  1. Norman D. Carter and Cecilia P. Carter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
  2. John A. Grimes v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
  3. Reverend W. Eugene Scott v. Evelle J. YoungerCourt of Appeals for the Ninth Circuit · 1984
  4. Galloway Farms, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 1987
  5. Coghlan v. StarkeyCourt of Appeals for the Fifth Circuit · 1988

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

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