Legal Opinion
Estate of Liftin v. United States
United States Court of Federal Claims
Decided May 17, 2013No. 10-589PublishedCited by 5 opinions
1Opinion of the Court
Estate Tax Refund Claim; Reasonable Cause for Late Filing; Reasonable Reliance on Advice of Counsel; Substantial Variance; 26 U.S.C. § 6651; United States v. Boyle, 469 U.S. 241 (1985); Estate of La Meres v. Comm’r, 98 T.C. 294 (1992).
OPINION AND ORDER
GEORGE W. MILLER, Judge
Before the Court for decision in this tax refund ease ax-e the parties’ cross-motions for summary judgment. The parties dispute whether the Internal Revenue Service (“IRS”) eon-ectly assessed a late-filing penalty. Plaintiff assex-ts that, since it relied on advice fx-om its attorney that its i-eturn was not yet due, its…
2Cases cited25 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
- Ricci v. DeStefanoSupreme Court of the United States · 2009
- United States v. BoyleSupreme Court of the United States · 1985
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3Cited by5 opinions
- Estate of Liftin v. United StatesCourt of Appeals for the Federal Circuit · 2014
- Gene H. Yamagata v. the United States 07-698t andUnited States Court of Federal Claims · 2014
- Andrews v. United StatesUnited States Court of Federal Claims · 2021
- Estate of Liftin v. United StatesCourt of Appeals for the Federal Circuit · 2014
- Oosterwijk v. United StatesDistrict Court, D. Maryland · 2022