Legal Opinion
I & O Publishing Co., Inc., and Wallace Ward v. Commissioner of Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided December 16, 1997No. 96-70117PublishedCited by 10 opinions
1Opinion of the Court
CANBY, Circuit Judge.
Wallace Ward appeals a decision of the Tax Court. Ward argues that the Tax Court violated the Double Jeopardy Clause by imposing an addition to tax for fraud under 26 U.S.C. § 6653(b) (1986), when he had previously been convicted of tax evasion for the same taxable years. He also challenges the Tax Court’s conclusion that it lacked jurisdiction to review the IRS’s jeopardy assessments against him. Finally, he asserts that the Tax Court erred in accepting the Commissioner’s determination of his tax deficiencies. This court has appellate jurisdiction under 26 U.S.C. § 7482…
2Cases cited14 opinions
- United States v. HalperSupreme Court of the United States · 1989
- Austin v. United StatesSupreme Court of the United States · 1993
- Helvering v. MitchellSupreme Court of the United States · 1938
- Department of Revenue of Mont. v. Kurth RanchSupreme Court of the United States · 1994
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
9 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Kevin J. Morse v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eighth Circuit · 2005
- Estate of Frank Branson, Deceased Mary M. March v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
- United States v. BoyceDistrict Court, S.D. California · 2001
- Louis v. CommissionerCourt of Appeals for the Ninth Circuit · 1999
- John R. Louis v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
5 more not listed; retrieve them via the Exa API.