Legal Opinion

Heaton v. United States

District Court, E.D. Washington

Decided July 22, 1983No. C-79-246PublishedCited by 2 opinions

1Opinion of the Court

ORDER AND JUDGMENT

BILBY, District Judge,

sitting by designation.

This action was brought by plaintiffs seeking a refund of taxes, penalties and interest which they claim was erroneously assessed against them by the United States. Jurisdiction is based on 28 U.S.C. § 1346(a)(1).

Prior to October 1, 1974, the plaintiffs operated their farm as a sole proprietorship. On October 1,1974, plaintiffs formed Heaton Farms, Inc., a corporation, in order to obtain the advantages of limited liability, corporate fringe benefits, and estate planning flexibility. Heaton Farms, Inc. continues to operate as a…

2Cases cited10 opinions

  1. Helvering v. HorstSupreme Court of the United States · 1940
  2. Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930
  3. Achiro v. CommissionerUnited States Tax Court · 1981
  4. Foster v. Comm'rUnited States Tax Court · 1983
  5. Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952

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3Cited by2 opinions

  1. Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
  2. Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985

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