Legal Opinion
John M. Capozzi v. United States
Court of Appeals for the Second Circuit
Decided December 8, 1992No. 178, Docket 92-6106PublishedCited by 19 opinions
1Opinion of the Court
MESKILL, Chief Judge:
Appellant John M. Capozzi appeals from a decision of the United States District Court for the District of Connecticut, Daly, J., granting summary judgment in favor of the United States. The court held that the five year limitations period contained in 28 U.S.C. § 2462 does not apply to the assessment of penalties under 26 U.S.C. § 6700 (hereinafter “IRC § 6700”). Capozzi does not contend that any genuine issue of material fact is in dispute, but argues that the district court erred as a matter of law.
We hold that 28 U.S.C. § 2462 places no time limit on the government’s…
2Cases cited8 opinions
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- E. I. Dupont De Nemours & Co. v. DavisSupreme Court of the United States · 1924
- United States v. Bertram L. PodellCourt of Appeals for the Second Circuit · 1978
- Western Reserve Oil & Gas Co. v. NewCourt of Appeals for the Ninth Circuit · 1985
- Brewer v. United StatesDistrict Court, S.D. New York · 1991
3 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Securities & Exchange Commission v. LorinDistrict Court, S.D. New York · 1994
- Westnau Land Corp. v. U.S. Small Business Administration, as an Agency of the United States of AmericaCourt of Appeals for the Second Circuit · 1993
- In Re WhiteUnited States Bankruptcy Court, D. Connecticut · 1994
- 3M Co. (Minnesota Mining & Manufacturing) v. BrownerCourt of Appeals for the D.C. Circuit · 1994
- In Re Mdl-731--Tax Refund Litigation Of Organizers And Promoters Of Investment Plans Involving Book Properties Leasing. Barrister AssociatesCourt of Appeals for the Second Circuit · 1993
14 more not listed; retrieve them via the Exa API.