§Why CasetextPricing

United States of America v. Bedford et al

MOTION for summary judgment

15 Cited authorities

  1. United States v. National Bank of Commerce

    472 U.S. 713 (1985)   Cited 822 times   5 Legal Analyses
    Holding that the IRS may place a lien on joint bank accounts for delinquent federal income taxes owed by only one of the persons whose name is on the joint account

  2. United States v. Rodgers

    461 U.S. 677 (1983)   Cited 876 times   4 Legal Analyses
    Holding that § 7403 contemplates "the recognition of third-party interests through the mechanism of judicial valuation and distribution"

  3. Walker v. Darby

    911 F.2d 1573 (11th Cir. 1990)   Cited 2,156 times
    Holding that circumstantial evidence may be used to prove a wiretap claim, including actual interception

  4. Welch v. Helvering

    290 U.S. 111 (1933)   Cited 3,713 times   64 Legal Analyses
    Holding that the Commissioner's determinations are presumed to be correct, and the taxpayer bears the burden of proving them wrong

  5. United States v. Bess

    357 U.S. 51 (1958)   Cited 563 times   1 Legal Analyses
    Holding that no federal tax lien could attach to proceeds of the taxpayer's life insurance policy because "[i]t would be anomalous to view as `property' subject to lien proceeds never within the insured's reach to enjoy"

  6. U.S. v. Chila

    871 F.2d 1015 (11th Cir. 1989)   Cited 183 times
    Holding that where the taxpayer "fail to establish affirmatively that the notice was not sent," the government's submission of a Form 4340 certifying the mailing of such a notice was "clear" evidence that such notice was sent and was sufficient to support a grant of summary judgment

  7. Baptiste v. C.I.R

    29 F.3d 1533 (11th Cir. 1994)   Cited 53 times   1 Legal Analyses
    Finding that transferee liability for the estate tax is not a tax liability but rather "an independent liability"

  8. United States v. Rivera

    No. CIV 14-0579 JB/CG (D.N.M. Jun. 30, 2015)   Cited 20 times
    Rejecting "lower-case-name" argument "as has every court to ever hear it"

  9. U.S. v. Dixon

    672 F. Supp. 503 (M.D. Ala. 1987)   Cited 60 times
    In United States v. Dixon, 672 F. Supp. 503 (M.D.Ala. 1987), subsequently affirmed by a per curiam opinion of this Court, 849 F.2d 1478 (11th Cir. 1988), the taxpayer claimed that the absence of a Form 23 C prevented the assessment from being valid.

  10. Olster v. C.I.R

    751 F.2d 1168 (11th Cir. 1985)   Cited 50 times

    No. 83-5706. January 28, 1985. Rehearing Denied March 7, 1985. Andrew H. Moriber, Kenneth M. Bloom, Miami, Fla., for petitioner-appellant. William H. Connett, Acting Chief Counsel, Robert B. Miscavich, Senior Tech. Reviewer, Tax Litigation Div., I.R.S., Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, David English Carmack, Joan I. Oppenheimer, Appellate Sect., Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee. Appeal from the Decision of the United States

  11. Rule 56 - Summary Judgment

    Fed. R. Civ. P. 56   Cited 328,986 times   158 Legal Analyses
    Holding a party may move for summary judgment on any part of any claim or defense in the lawsuit

  12. Section 6662 - Imposition of accuracy-related penalty on underpayments

    26 U.S.C. § 6662   Cited 6,299 times   66 Legal Analyses
    Defining "negligence" as "any failure to make a reasonable attempt to comply with the provisions of this title"

  13. Section 7403 - Action to enforce lien or to subject property to payment of tax

    26 U.S.C. § 7403   Cited 1,124 times
    Granting federal courts the authority to order a foreclosure and sale of a property subject to a tax lien