Legal Opinion

Rockefeller v. United States

District Court, E.D. Arkansas

Decided December 10, 1982No. LR C 81 775PublishedCited by 16 opinions

1Opinion of the Court

ORDER

OVERTON, District Judge.

This is an action for the recovery of taxes and interest assessed against and paid by the plaintiff pursuant to 26 U.S.C. § 4941(a)(1). The parties have entered into a stipulation of fact and have agreed to present the case to the Court on the following issues: (1) whether 26 U.S.C. § 4941 is constitutional; (2) whether Treas.Reg. Sec. 53 — 4941(d)-l(b)(3) is constitutional; (3) whether plaintiff is a disqualified person under § 4941; and (4) whether the exactions assessed against the plaintiff pursuant to § 4941(a)(1) are penalties, not taxes, for the purpose of…

2Cases cited17 opinions

  1. Connally v. General Construction Co.Supreme Court of the United States · 1926
  2. Winters v. New YorkSupreme Court of the United States · 1948
  3. Joseph Burstyn, Inc. v. WilsonSupreme Court of the United States · 1952
  4. J. W. Hampton, Jr., & Co. v. United StatesSupreme Court of the United States · 1928
  5. United States v. L. Cohen Grocery Co.Supreme Court of the United States · 1921

12 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. Rutland v. CommissionerUnited States Tax Court · 1987
  2. Estate of Reis v. CommissionerUnited States Tax Court · 1986
  3. CITIZENS TO ESTABLISH REFORM PARTY v. PriestDistrict Court, E.D. Arkansas · 1996
  4. Lambos v. CommissionerUnited States Tax Court · 1987
  5. Winthrop P. Rockefeller, Appellant/cross v. United States of America, Appellee/crossCourt of Appeals for the Eighth Circuit · 1983

11 more not listed; retrieve them via the Exa API.

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