Legal Opinion

United States v. Roderick J. MacKenzie Malcolm L. MacKenzie and David H. MacKenzie Inc.

Court of Appeals for the Second Circuit

Decided January 21, 1986No. 216, 217, Dockets 85-1023, 1024PublishedCited by 39 opinions

1Opinion of the Court

OAKES, Circuit Judge:

This is an appeal from convictions for conspiracy to defraud the United States, filing fraudulent tax returns, and aiding and assisting the filing of fraudulent returns, all in connection with paying employees without withholding taxes. Appellants contend that the underlying withholding statute and regulations are unconstitutionally vague, that a provision of the Revenue Act of 1978 offers a “safe haven” defense that either barred this prosecution or should have been submitted to the jury; that the jury was improperly charged that deliberate ignorance would satisfy the…

2Cases cited27 opinions

  1. Coolidge v. New HampshireSupreme Court of the United States · 1971
  2. Sandstrom v. MontanaSupreme Court of the United States · 1979
  3. Connally v. General Construction Co.Supreme Court of the United States · 1926
  4. Kolender v. LawsonSupreme Court of the United States · 1983
  5. Francis v. FranklinSupreme Court of the United States · 1985

22 more not listed; retrieve them via the Exa API.

3Cited by39 opinions

  1. United States v. Beverly J. Ramsey, Michael J. Marshall, Stuart A. McCreary and James Joseph O'DOnnellCourt of Appeals for the Seventh Circuit · 1986
  2. United States v. John A. Gambone, Sr. A/K/A Jack John A. Gambone, Sr., United States of America v. Anthony Gambone A/K/A Tony Anthony GamboneCourt of Appeals for the Third Circuit · 2003
  3. United States v. Joseph Aracri, John Papandon, and Anthony ZummoCourt of Appeals for the Second Circuit · 1992
  4. United States v. George GotchisCourt of Appeals for the Second Circuit · 1986
  5. United States v. Irwin A. SchiffCourt of Appeals for the Second Circuit · 1986

34 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API