Legal Opinion
Kellems v. United States
District Court, D. Connecticut
Decided April 25, 1951No. Civ. A. 2805PublishedCited by 31 opinions
1Opinion of the Court
HINCKS, Chief Judge.
Whether the penalty statute, 26 U.S.C.A. § 2707(a) is applicable to a case of _ non-compliance with the Withholding Act, 26 U.S.C.A. § 1621 et seq., is a question which I decided adversely to the plaintiffs for reasons stated in my preliminary memorandum and order of October 26, 19S0, denying the plaintiffs’ motion for judgment. ’
The “government”, which for purposes of this memorandum may be taken as a comprehensive designation of both defendants, has taken the position throughout, and still adheres to.the position, that an intentional and deliberate non-compliance, which…
2Cases cited2 opinions
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Genesee Valley Gas Co. v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1950
3Cited by31 opinions
- Edward J. Bloom v. United StatesCourt of Appeals for the Ninth Circuit · 1960
- Arthur King Wilson v. United StatesCourt of Appeals for the Ninth Circuit · 1958
- Robert White v. The United StatesUnited States Court of Claims · 1967
- Hal C. Frazier v. United StatesCourt of Appeals for the Fifth Circuit · 1962
- Sherman-Reynolds, Inc. v. MahinIllinois Supreme Court · 1970
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