Legal Opinion
John A. Sage v. United States
Court of Appeals for the Fifth Circuit
Decided August 13, 1990No. 89-2780, 89-6090PublishedCited by 64 opinions
1Opinion of the Court
GEE, Circuit Judge:
Appellant John A. Sage obtained judgment in federal district court against the United States, the central holding of which was that the three-year statute of limitations in Section 6501(a) of the Internal Revenue Code barred the IRS’s assessment of penalties against him pursuant to Section 6700. From that judgment the United States now appeals contending, in the main, that Section 6501(a) does not apply to bar Section 6700 penalties and that the only curb on the government’s penalty-assessment power lies in the doctrine of laches (which was not raised by Sage in district…
2Cases cited14 opinions
- Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- United States v. Munsey Trust Co.Supreme Court of the United States · 1947
- United States v. The City of Palm Beach GardensCourt of Appeals for the Fifth Circuit · 1981
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3Cited by64 opinions
- Seven-Sky v. HolderCourt of Appeals for the D.C. Circuit · 2011
- Paul F. Belloff v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
- James M. Mullikin v. United StatesCourt of Appeals for the Sixth Circuit · 1992
- Albert A. Stevens v. United States of America, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1995
59 more not listed; retrieve them via the Exa API.