Legal Opinion
Anthony C. And Mildred M. Licari v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided October 7, 1991No. 90-70258PublishedCited by 22 opinions
1Opinion of the Court
FLETCHER, Circuit Judge:
OVERVIEW
Taxpayers, Anthony and Mildred Licari, appeal the Tax Court’s application of a 25% penalty pursuant to 26 U.S.C. § 6661 to their undisputed understatement of tax liability. The Licaris contend that retroactive application of the 25% penalty, rather than the 10% penalty rate that applied at the time they filed their tax returns, violated their constitutional rights. 1 We affirm.
FACTS
In a Notice of Deficiency dated April 11, 1986, the Internal Revenue Service (“IRS”) determined that the Licaris had substantially understated their income in taxable years 1981…
2Cases cited14 opinions
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- Lindsley v. Natural Carbonic Gas Co.Supreme Court of the United States · 1911
- Usery v. Turner Elkhorn Mining Co.Supreme Court of the United States · 1976
- Helvering v. MitchellSupreme Court of the United States · 1938
- Pension Benefit Guaranty Corporation v. RA Gray & Co.Supreme Court of the United States · 1984
9 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- John M. Quarty, Personal Representative of the Estate of Angele C. Quarty Elizabeth B. Cherne v. United StatesCourt of Appeals for the Ninth Circuit · 1999
- William D. Little v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1997
- J. Thomas Zaber, On Behalf Of Himself And All Others Similarly Situated Vs. City Of Dubuque, IowaSupreme Court of Iowa · 2010
- Montana Rail Link, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1996
- Enterprise Leasing Co. v. Arizona Department of RevenueCourt of Appeals of Arizona · 2008
17 more not listed; retrieve them via the Exa API.