Legal Opinion
Churchill Farms, Inc. v. Orr
District Court, E.D. Louisiana
Decided February 18, 1971No. Civ. A. No. 70-3140PublishedCited by 1 opinion
1Opinion of the Court
RUBIN, District Judge:
By motion to dismiss and, alternatively, for summary judgment, the United States seeks to dispose of a unique proceeding brought against it by a taxpayer. The motions are well founded.
These facts are undisputed: On March 25, 1970, the Tax Court held both plaintiff and another taxpayer liable for the personal holding company tax imposed under Sections 541-547, Internal Revenue Code of 1954. (26 U.S.C. Secs. 541-547). Both taxpayers filed notices of appeal to the Fifth Circuit Court of Appeals, but neither filed the bond required by IRC Section 7485. Therefore on October…
2Cases cited6 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Lawlor v. National Screen Service Corp.Supreme Court of the United States · 1955
- Sprague Electric Company v. The Tax Court of the United StatesCourt of Appeals for the First Circuit · 1965
- Sprague Electric Company v. Tax Court of United StatesDistrict Court, D. Massachusetts · 1964
- Baglivo v. Commissioner of Internal RevenueDistrict Court, E.D. Pennsylvania · 1964
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Lucille P. Kahn v. United StatesCourt of Appeals for the Second Circuit · 1978