Legal Opinion
Agbanc, Ltd. v. United States
District Court, D. Arizona
Decided November 16, 1988No. Civ. 87-2235 PHX RCB, Civ. 87-2236 PHX RCB and Civ. 87-2238 PHX RCBPublishedCited by 11 opinions
1Opinion of the Court
ORDER
BROOMFIELD, District Judge.
INTRODUCTION
Plaintiffs Agbanc Ltd. (“Agbanc”), Am-banc Ltd. (“Ambanc”) and John C. McDonnell (“McDonnell”) brought suit against defendant, United States of America, under 26 U.S.C. 6703, to contest penalty assessments made against them by the Internal Revenue Service pursuant to 26 U.S.C. 6700 which governs abusive tax shelters. Plaintiffs acquired standing by paying the required jurisdictional amounts (15% of each of the penalties pursuant to Code Section 6703) and filing a Claim for Refund with the IRS which was denied. Plaintiffs subsequently instituted the…
2Cases cited15 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
- DelCostello v. International Brotherhood of TeamstersSupreme Court of the United States · 1983
- United States v. Bertram L. PodellCourt of Appeals for the Second Circuit · 1978
- United States v. The City of Palm Beach GardensCourt of Appeals for the Fifth Circuit · 1981
10 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
- James M. Mullikin v. United StatesCourt of Appeals for the Sixth Circuit · 1992
- In Re Tax Refund LitigationDistrict Court, E.D. New York · 1991
- Emanuel v. United StatesDistrict Court, N.D. Illinois · 1989
- United States v. Estate Preservation ServicesCourt of Appeals for the Ninth Circuit · 2000
6 more not listed; retrieve them via the Exa API.