Legal Opinion
United States v. James C. Russell, Earhl R. Schooff, and Lawrence M. Richey
Court of Appeals for the Ninth Circuit
Decided November 18, 1986No. 86-3013, 86-3014 and 86-3015PublishedCited by 22 opinions
1Opinion of the Court
FLETCHER, Circuit Judge:
Plaintiff United States appeals the district court’s dismissal of 12 counts of a 28-count indictment. The district court held that the defendants lacked fair notice of the illegality of the tax avoidance schemes they developed and promoted, and that they accordingly could not have willfully violated the statute. We reverse and remand for trial.
BACKGROUND
Frank Forrester developed tax shelter programs designed to reduce taxpayers’ income tax liabilities. Under Forrester’s primary program, the “personal services contract,” taxpayers would “sell” their life services to…
2Cases cited16 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- United States v. PomponioSupreme Court of the United States · 1976
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
11 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- United States v. NosalCourt of Appeals for the Ninth Circuit · 2012
- United States v. David L. Smith, United States of America v. Herbert A. BatesCourt of Appeals for the Ninth Circuit · 2005
- United States v. Arthur P. Tranakos, United States of America v. William PilgrimCourt of Appeals for the Tenth Circuit · 1990
- United States v. Walter D. Brodie, United States of America v. Nancy A. BrodieCourt of Appeals for the Ninth Circuit · 1988
- United States v. Allan BorenCourt of Appeals for the Ninth Circuit · 2002
17 more not listed; retrieve them via the Exa API.