Legal Opinion
Donnell R. Mattingly v. United States
Court of Appeals for the Eighth Circuit
Decided March 13, 1991No. 90-1538PublishedCited by 37 opinions
1Opinion of the Court
HENLEY, Senior Circuit Judge.
This appeal arises from a jury verdict rendered in federal district court 1 resulting in the assessment of $54,000.00 in tax penalties against appellant under 26 U.S.C. § 6701 (the Internal Revenue Code, or I.R.C.) for supplying valuation overstatements in connection with tax returns which claimed illegitimate investment tax credits. 2 The issues before us are ones of first impression regarding questions of (1) whether the government’s evidentiary burden of proof under § 6701 is by a preponderance of the evidence, (2) whether and to what extent a “willful…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Herman & MacLean v. HuddlestonSupreme Court of the United States · 1983
- Helvering v. TaylorSupreme Court of the United States · 1935
- Rosebud Sioux Tribe v. A & P Steel, Inc.Court of Appeals for the Eighth Circuit · 1984
- Clayton M. Korecky, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
15 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- Tiffany (NJ) Inc. v. eBay Inc.Court of Appeals for the Second Circuit · 2010
- United States v. LightyCourt of Appeals for the Fourth Circuit · 2010
- United States v. Paul J. Leahy United States of America v. Timothy Smith United States of America v. Dantone, Inc.Court of Appeals for the Third Circuit · 2006
- Everett W. Berger v. United StatesCourt of Appeals for the Second Circuit · 1996
- Commodity Futures Trading Commission v. SidotiCourt of Appeals for the Eleventh Circuit · 1999
32 more not listed; retrieve them via the Exa API.