Legal Opinion

Clay v. United States

Court of Appeals for the Sixth Circuit

Decided December 20, 1999No. 99-3175PublishedCited by 21 opinions

1Opinion of the Court

OPINION

CONTIE, Circuit Judge.

Petitioners-appellants, Ezekiel Clay IV, et al., appeal the judgment of the district court dismissing their petition to quash IRS summonses to a third-party record-keeper because the petition was untimely filed. For the following reasons, we affirm.

I

The Internal Revenue Service (“IRS”), pursuant to an income tax investigation of petitioner Clay and several trusts of which he is the trustee (“petitioners”), issued seven summonses to a third-party record-keeper, Key Bank of Dayton, Ohio, on June 16, 1998, requesting information regarding the tax liability of Mr.…

2Cases cited13 opinions

  1. United States v. TestanSupreme Court of the United States · 1976
  2. United States v. SherwoodSupreme Court of the United States · 1941
  3. Lehman v. NakshianSupreme Court of the United States · 1981
  4. United States v. DalmSupreme Court of the United States · 1990
  5. United States Department of Energy v. OhioSupreme Court of the United States · 1992

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

3Cited by21 opinions

  1. Kenneth Bernard Rouse v. R.C. Lee, Warden, Central Prison, Raleigh, North CarolinaCourt of Appeals for the Fourth Circuit · 2003
  2. Kimberly Gaetano v. United StatesCourt of Appeals for the Sixth Circuit · 2021
  3. Kevin Brott v. United StatesCourt of Appeals for the Sixth Circuit · 2017
  4. Berman v. United StatesCourt of Appeals for the First Circuit · 2001
  5. Velez-Diaz v. United StatesCourt of Appeals for the First Circuit · 2007

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API