Palmer v. United States Internal Revenue Service
Court of Appeals for the Ninth Circuit
1Opinion of the Court
O’SCANNLAIN, Circuit Judge:
We must decide whether the Internal Revenue Service made proper deficiency determinations and assessments for unpaid taxes against non-cooperative taxpayers.
I
Paul and Angela Palmer failed to file tax returns from which their income could be determined for the years 1976 through 1979. Internal Revenue Service (“IRS”) agents attempted to meet with the Palmers to gather income information, but the Palmers did not attend the scheduled meeting.
IRS employees then conducted an investigation seeking income information from the four unreported years, with limited success.…
2Cases cited17 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- United States v. Chemical Foundation, Inc.Supreme Court of the United States · 1926
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- William H. And Avilda L. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
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3Cited by5 opinions
- Angela Palmer, in Her Representative Capacity as Trustee of the Paul B. Palmer, Jr. Family Preservation Trust v. United States Internal Revenue Service, United States of America, Counter-Claimant v. Paul B. Palmer, Jr., Counter-DefendantCourt of Appeals for the Ninth Circuit · 1997
- Xenakis v. United States (In Re Xenakis)United States Bankruptcy Court, W.D. Pennsylvania · 2001
- Lunnon v. United StatesDistrict Court, D. New Mexico · 2020
- O.S.C. & Associates, Inc., D.B.A. Olympic Screen Crafts v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- O.S.C. & Associates, Inc., D.B.A. Olympic Screen Crafts v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999