Leo Manzoli and Mary Ann Manzoli v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
1Opinion of the Court
TORRUELLA, Circuit Judge.
Leo and Mary Ann Manzoli appeal from the Tax Court’s decision sustaining tax deficiencies assessed against them by the Commissioner of Internal Revenue (“Commissioner”). The issues are various and will be discussed seriatim.
FACTS
On June 13, 1984, the Grand Jury of the United States District Court for the District of Massachusetts indicted Leo Manzoli and Mary Ann Manzoli for willfully attempting to evade and defeat their federal income tax liabilities for the taxable years of 1977 and 1978 in violation of 26 U.S.C. § 7201. On January 3, 1986, Mr. Manzoli pled guilty…
2Cases cited32 opinions
- Foman v. DavisSupreme Court of the United States · 1962
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- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Glasser v. United StatesSupreme Court of the United States · 1942
- Allen v. McCurrySupreme Court of the United States · 1980
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