Legal Opinion

Sims v. United States

District Court, M.D. Tennessee

Decided February 20, 1991No. 3:89-0461PublishedCited by 1 opinion

1Opinion of the Court

MEMORANDUM

WISEMAN, Chief Judge.

This action was brought by Sims for refund of withholding taxes paid on gambling winnings in the amount of $4,018.99 pursuant to 26 U.S.C. § 3402(q)(l). The government counterclaimed for the unpaid balance of the assessments against Sims in the amount of $959,790.83, plus statutory *1049additions. Sims also seeks preliminary and permanent injunctions restraining the Internal Revenue Service (“IRS”) from collecting the balance of the taxes, penalty, and interest.

This Court held a bench trial on December 11, 1990. Pursuant to the Court’s direction at the close of the…

2Cases cited13 opinions

  1. Ashwander v. Tennessee Valley AuthoritySupreme Court of the United States · 1936
  2. Nebbia v. New YorkSupreme Court of the United States · 1934
  3. United States v. JanisSupreme Court of the United States · 1976
  4. United States v. LeeSupreme Court of the United States · 1982
  5. Anthony A. Calderone, Clark Hornbaker, Plaintiffs-Counterclaim Defendants v. United States of America, Defendant-Counter-Claimant-AppellantCourt of Appeals for the Sixth Circuit · 1986

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3Cited by1 opinion

  1. Chicago Milwaukee Corp. v. United StatesUnited States Court of Federal Claims · 1996

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