Legal Opinion
Severo v. Commissioner
Court of Appeals for the Ninth Circuit
Decided November 20, 2009No. 08-70817PublishedCited by 12 opinions
1Opinion of the Court
HALL, Circuit Judge:
Taxpayers Michael and Georgina Severo (“the Severos”) appeal from the decision of the United States Tax Court granting summary judgment in favor of the Internal Revenue Service (“IRS”) and permitting the IRS to proceed with its collection action relating to the Severos’ 1990 tax liability. We have jurisdiction pursuant to 26 U.S.C. § 7482(a)(1) and affirm the decision of the Tax Court.
I. Background
The Severos’ 1990 joint tax return, after extensions, was due October 15, 1991. They filed their tax return three days late without paying most of their taxes. On November 18,…
2Cases cited11 opinions
- Young v. United StatesSupreme Court of the United States · 2002
- Barboza v. New Form, Inc. (In Re Barboza)Court of Appeals for the Ninth Circuit · 2008
- West v. United States (In re West)Court of Appeals for the Ninth Circuit · 1993
- Mangano v. United StatesCourt of Appeals for the Ninth Circuit · 2008
- Talley Industries Inc. Consolidated Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1997
6 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- In Re JonesCourt of Appeals for the Ninth Circuit · 2011
- Chenault v. Comm'rUnited States Tax Court · 2011
- California Franchise Tax Board v. Kendall (In Re Jones)Court of Appeals for the Ninth Circuit · 2011
- In re PaxtonUnited States Bankruptcy Court, N.D. California · 2019
- Rehn v. Comm'rUnited States Tax Court · 2016
7 more not listed; retrieve them via the Exa API.