Legal Opinion
Jay N. Karpa Elizabeth J. Karpa v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided July 27, 1990No. 89-1577PublishedCited by 23 opinions
1Opinion of the Court
PHILLIPS, Circuit Judge:
Jay and Elizabeth Karpa appeal from the Tax Court’s decision upholding the Commissioner’s proposed imposition of a tax penalty under former I.R.C. § 6661(a). The Karpas argued that the § 6661(a) tax penalty for substantial understatement of tax liability, as applied retroactively to their 1984 return, was unconstitutional as violative of the ex post facto clause. Both parties moved for judgment on the pleadings, and the Tax Court granted the Commissioner’s motion. We agree that former § 6661(a) does not violate the ex post facto clause and therefore affirm.
I
The…
2Cases cited13 opinions
- Singleton v. WulffSupreme Court of the United States · 1976
- Calder v. BullSupreme Court of the United States · 1798
- United States v. HalperSupreme Court of the United States · 1989
- Collins v. YoungbloodSupreme Court of the United States · 1990
- Hormel v. HelveringSupreme Court of the United States · 1941
8 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Margaret Nealon v. Michael P.W. Stone, Secretary of the Army, Clarence Thomas, Chairman, Equal Opportunity CommissionCourt of Appeals for the Fourth Circuit · 1992
- William D. Little v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1997
- Joseph P. Caulfield v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1994
- McNichols v. CommissionerCourt of Appeals for the First Circuit · 1993
- United States v. William J. Alt, M.D. Rosalinda Alt Karen Alt Robert W. Alt, William J. Alt, M.D.Court of Appeals for the Sixth Circuit · 1996
18 more not listed; retrieve them via the Exa API.