Legal Opinion
Security Industrial Insurance Company v. United States of America
Court of Appeals for the Fifth Circuit
Decided October 23, 1987No. 86-3806PublishedCited by 20 opinions
1Opinion of the Court
GEE, Circuit Judge:
Security Industrial Insurance Co. (“the taxpayer”) appeals the dismissal of this Enochs suit 1 seeking to enjoin collection of federal income tax. We remand for dismissal.
I
The taxpayer and the government entered into several agreements extending the three-year statute of limitations for the 1973 tax year. Under the last of these agreements, the limitation would run in December 1982. The government issued a statutory notice of deficiency to the taxpayer 46 days before the end of the extended period. The taxpayer filed a timely petition in the United States Tax Court for a…
2Cases cited20 opinions
- Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
- Griffin v. United StatesSupreme Court of the United States · 1949
- John Thomas Stanford v. Everett Utley, D/B/A Utley Trucking Company and E. C. HoodCourt of Appeals for the Eighth Circuit · 1965
- Carolyn Brafman v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Jersey Shore State Bank v. United StatesSupreme Court of the United States · 1987
15 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- United States v. John A. ChilaCourt of Appeals for the Eleventh Circuit · 1989
- Joseph F. Purcell, Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-AppelleeCourt of Appeals for the Ninth Circuit · 1993
- United States v. Malcolm McCallumCourt of Appeals for the Fifth Circuit · 1992
- In Re Princo CorporationCourt of Appeals for the Federal Circuit · 2007
- United States v. Joseph H. HansCourt of Appeals for the Sixth Circuit · 1990
15 more not listed; retrieve them via the Exa API.