Legal Opinion
Davis v. Commissioner of Internal Revenue Service
District Court, M.D. Alabama
Decided February 13, 1987No. Civ. A. 86-T-303-NPublishedCited by 2 opinions
1Opinion of the Court
MEMORANDUM OPINION
MYRON H. THOMPSON, District Judge.
In this action, petitioners William Davis and Virginia Owens (formerly Davis) seek to have the court enjoin the Commissioner of the Internal Revenue Service (IRS) from collecting taxes and penalties assessed against them for the year 1980. The cause is now before the court on respondent Commissioner’s motion for summary judgment. For reasons that follow, the court is of the opinion that the motion is due to be granted.
I
In 1980, Davis and Owens, who were at the time married to each other, filed a joint tax return, listing their residence as…
2Cases cited19 opinions
- Weinberger v. Romero-BarceloSupreme Court of the United States · 1982
- Enochs v. Williams Packing & Navigation Co.Supreme Court of the United States · 1962
- Bob Jones University v. SimonSupreme Court of the United States · 1974
- Commissioner v. ShapiroSupreme Court of the United States · 1976
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
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3Cited by2 opinions
- Miller v. CommissionerUnited States Tax Court · 1990
- Miller v. CommissionerUnited States Tax Court · 1990