Legal Opinion
Randazzo v. United States Department of the Treasury Internal Revenue Service
District Court, W.D. Pennsylvania
Decided March 15, 1984No. Civ. A. 83-2020PublishedCited by 12 opinions
1Opinion of the Court
OPINION
COHILL, District Judge.
Currently before us is plaintiffs Motion to Amend Order to Include All Costs, Interest and Attorneys’ Fees filed pursuant to 26 U.S.C. § 7430. After careful consideration of the parties’ memoranda and the applicable law, we will deny the plaintiff’s motion.
The plaintiff brought this action under 26 U.S.C. § 7429 for a summary review of the income tax assessment made against him by the Internal Revenue Service (“IRS”) for the period of January 1, 1983 to May 25, 1983. The amount of the assessment was $29,342.00.
The assessment was made subsequent to a seizure of…
2Cases cited4 opinions
- Natural Resources Defense Council, Inc. v. U.S. Environmental Protection Agency, Chemical Manufacturers Association, IntervenorsCourt of Appeals for the Third Circuit · 1983
- Fidelity Construction Company v. The United StatesCourt of Appeals for the Federal Circuit · 1983
- BROAD AVENUE LAUNDRY AND TAILORING, Petitioner, v. the UNITED STATES, RespondentCourt of Appeals for the Federal Circuit · 1982
- Watkins v. HarrisDistrict Court, E.D. Pennsylvania · 1983
3Cited by12 opinions
- Kaufman v. EggerDistrict Court, D. Maine · 1984
- Zinniel v. CommissionerCourt of Appeals for the Seventh Circuit · 1989
- James J. Randazzo v. United States of America, Department of the Treasury, Internal Revenue ServiceCourt of Appeals for the Third Circuit · 1984
- John C. Zinniel v. Commissioner Of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
- McWilliams v. CommissionerUnited States Tax Court · 1995
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