Donna L. Todd v. United States of America and R.S. Wintrode, Jr., District Director, Internal Revenue Service
Court of Appeals for the Ninth Circuit
1Opinion of the Court
ORDER
The court’s opinion filed October 20, 1986, and reported at 802 F.2d 1152-58 (9th Cir.1986), is hereby withdrawn and replaced with the attached opinion.
OPINION
BEEZER, Circuit Judge:
This appeal is the result of a Bivens 1 action against IRS agents for damages arising out of a penalty imposed under 26 U.S.C. § 6702. The United States and the individual IRS agents appeal a partial denial of their motion for summary judgment. The district court dismissed Todd’s claims against the United States and the individual defendants acting in their “official” capacities on sovereign immunity grounds.…
2Cases cited23 opinions
- Harlow v. FitzgeraldSupreme Court of the United States · 1982
- Bivens v. Six Unknown Named Agents of Federal Bureau of NarcoticsSupreme Court of the United States · 1971
- Anderson v. CreightonSupreme Court of the United States · 1987
- Cohen v. Beneficial Industrial Loan Corp.Supreme Court of the United States · 1949
- Mitchell v. ForsythSupreme Court of the United States · 1985
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- Wages v. Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1990
- Phillip Fry, Susan Fry v. Olin Melaragno, David W. Otto, Mark Barnes, Mark PenderyCourt of Appeals for the Ninth Circuit · 1991
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