Legal Opinion
Carney v. Internal Revenue Service
Court of Appeals for the Fifth Circuit
Decided July 16, 2001No. 00-10746PublishedCited by 168 opinions
1Opinion of the Court
BENAVIDES, Circuit Judge:
John H. Carney appeals from an adverse summary judgment in his challenge to the validity of tax deficiency claims made against him by the Internal Revenue Service (IRS). The deficiencies stem from the IRS’s determination that certain partnership investments by Carney lacked economic substance, and hence could not support tax credits and depreciation deductions that Carney claimed. We AFFIRM the grant of summary judgment based on Carney’s Rule 36(a) deemed admission that the proof of claim filed by the IRS in his bankruptcy proceeding accurately described his tax…
2Cases cited27 opinions
- Ohler v. United StatesSupreme Court of the United States · 2000
- Rommie STULTS and Stephen Wallace, Plaintiffs-Appellants, v. CONOCO, INC. and Brad Burmaster, Defendants-AppelleesCourt of Appeals for the Fifth Circuit · 1996
- Willard Rushing and Patricia Rushing v. Kansas City Southern Railway CompanyCourt of Appeals for the Fifth Circuit · 1999
- James Skip Hulsey v. State of TexasCourt of Appeals for the Fifth Circuit · 1991
- American States Ins. Co. v. BaileyCourt of Appeals for the First Circuit · 1998
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3Cited by168 opinions
- Michael Perez v. Miami-Dade CountyCourt of Appeals for the Eleventh Circuit · 2002
- Michael J. Conlon v. United StatesCourt of Appeals for the Ninth Circuit · 2007
- In Re Louisiana Crawfish ProducersCourt of Appeals for the Fifth Circuit · 2017
- Batyukova v. DoegeCourt of Appeals for the Fifth Circuit · 2021
- Foust v. McNeillCourt of Appeals for the Fifth Circuit · 2002
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