Legal Opinion

United States v. Allen

Court of Appeals for the First Circuit

Decided January 6, 2012No. 10-2160, 10-2161PublishedCited by 18 opinions

1Opinion of the Court

BOUDIN, Circuit Judge.

Frederick and Kimberlee Allen — husband and wife — appeal from their convictions for tax-related offenses. For some years the Allens filed annual federal income tax returns reporting their income. However, for tax years 1997 through 1999, despite reportable income, the Allens filed returns reporting zero income. On the advice of their dentist, and their own research, they concluded that no provision of the Internal Revenue Code imposed “liability” on them for taxes, and attached this explanation to their returns.

Beginning in 1998, the Allens succeeded in stopping their…

2Cases cited9 opinions

  1. Cheek v. United StatesSupreme Court of the United States · 1991
  2. Bryan v. United StatesSupreme Court of the United States · 1998
  3. United States v. Ofray-CamposCourt of Appeals for the First Circuit · 2008
  4. United States v. Rivera-SantiagoCourt of Appeals for the First Circuit · 1989
  5. United States v. FrankhauserCourt of Appeals for the First Circuit · 1996

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3Cited by18 opinions

  1. United States v. MehannaCourt of Appeals for the First Circuit · 2013
  2. United States v. Paz-AlvarezCourt of Appeals for the First Circuit · 2015
  3. United States v. PowersCourt of Appeals for the First Circuit · 2012
  4. Rubenstein v. Int'l Value Advisers, LLCCourt of Appeals for the Second Circuit · 2020
  5. United States v. AdamsCourt of Appeals for the First Circuit · 2014

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