Legal Opinion

Pizzarello v. United States

Court of Appeals for the Second Circuit

Decided March 18, 1969No. 110, Docket 32532PublishedCited by 87 opinions

1Opinion of the Court

MOORE, Circuit Judge:

Emilio Pizzarello (appellant) appeals from an order of the District Court for the Southern District of New York, 285 F.Supp. 147, entered in an action to enjoin the levy of a jeopardy assessment1 for unpaid wagering taxes on money illegally seized by the United States (the Government). The order, entered on May 31, 1968, denied appellant’s application for a preliminary injunction against the levy on $125,882 in currency, obtained by Special Treasury Agents, to satisfy a tax assessment of $282,440.70. It also denied his application pursuant to 28 U.S.C. §§ 2282 and 2284…

2Cases cited33 opinions

  1. Boyd v. United StatesSupreme Court of the United States · 1886
  2. Silverthorne Lumber Co. v. United StatesSupreme Court of the United States · 1920
  3. Garrity v. New JerseySupreme Court of the United States · 1967
  4. Marchetti v. United StatesSupreme Court of the United States · 1968
  5. Helvering v. TaylorSupreme Court of the United States · 1935

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3Cited by87 opinions

  1. Commissioner v. ShapiroSupreme Court of the United States · 1976
  2. Jackson v. CommissionerUnited States Tax Court · 1979
  3. Suarez v. CommissionerUnited States Tax Court · 1972
  4. Raul Llorente v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1981
  5. Ramon Portillo and Dolores Portillo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991

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