Legal Opinion
Cyclone Drilling, Inc., a Wyoming Corporation v. Michael J. Kelley, as District Director of Internal Revenue Service for the Cheyenne District
Court of Appeals for the Tenth Circuit
Decided August 2, 1985No. 84-2300PublishedCited by 32 opinions
1Opinion of the Court
BARRETT, Circuit Judge.
Cyclone Drilling, Inc. (taxpayer) appeals from the district court’s Order of Dismissal (With Findings), which denied taxpayer the injunction it sought against Michael J. Kelly, District Director of Internal Revenue Service for the Cheyenne District (Mr. Kelly was sued in his official capacity; the defendant in this case will hereinafter be referred to as “the IRS”). The IRS’s motion to dismiss was filed pursuant to Fed.R. Civ.P. 12. Inasmuch as the motion was based on affidavits and other documents outside the pleadings, the district court properly treated the motion as…
2Cases cited19 opinions
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Fountain v. FilsonSupreme Court of the United States · 1949
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
14 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Monge v. CommissionerUnited States Tax Court · 1989
- William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- William D. Armstrong v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1994
- John P. Pomeroy v. United States of America, John P. Pomeroy and Frances E. Pomeroy, Cross-Appellants v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1989
- Gerald D. Ward and Joan Ward (Deceased) v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
27 more not listed; retrieve them via the Exa API.