32 Cited authorities

Celotex Corp. v. Catrett
477 U.S. 317 (1986) Cited 217,112 times 40 Legal Analyses
Holding that a movant's summary judgment motion should be granted "against a [nonmovant] who fails to make a showing sufficient to establish the existence of an element essential to that party's case, and on which that party will bear the burden of proof at trial"
Weinberger v. Romero-Barcelo
456 U.S. 305 (1982) Cited 1,776 times 4 Legal Analyses
Holding that Federal Water Pollution Control Act did not mandate injunctions against its violation
Evans v. Techs. Applications Serv.
80 F.3d 954 (4th Cir. 1996) Cited 3,201 times 1 Legal Analyses
Holding that the plaintiff's age discrimination claim did not relate back to the originally filed charge of sex discrimination
Commissioner v. Groetzinger
480 U.S. 23 (1987) Cited 372 times 23 Legal Analyses
Holding that a full-time gambler was engaged in a trade or business
Custer v. Pan American Life Ins. Co.
12 F.3d 410 (4th Cir. 1993) Cited 639 times
Holding that when the factual circumstances are undisputed, whether the facts suffice to demonstrate the existence of a plan as defined by ERISA is a question of law to be reviewed de novo
Teamsters Joint Council No. 83 v. Centra, Inc.
947 F.2d 115 (4th Cir. 1991) Cited 550 times
Holding a control group member liable for withdrawal liability because that entity was a member prior to confirmation as well as after
In re Carney
258 F.3d 415 (5th Cir. 2001) Cited 305 times
Finding that admissions by default are an appropriate basis for granting summary judgment
Coltec Industries, Inc. v. U.S.
454 F.3d 1340 (Fed. Cir. 2006) Cited 107 times 2 Legal Analyses
Holding that "the transaction to be analyzed is the one that gave rise to alleged tax benefit" and rejecting taxpayer's argument that economic substance test requires consideration of broader set of transactions
Langer v. Monarch Life Ins. Co.
966 F.2d 786 (3d Cir. 1992) Cited 128 times
Holding in part that district court erred in reading defendant's binding admissions too broadly
U.S. v. Raymond
228 F.3d 804 (7th Cir. 2000) Cited 80 times
Holding that the government had incurred a significant loss as a result of the administrative burden defendant placed on the IRS by causing it to respond to frivolous Freedom of Information Act requests, investigate unlawful tax evasion activities, and engage in collection efforts to obtain unpaid taxes
Section 636 - Jurisdiction, powers, and temporary assignment
28 U.S.C. § 636 Cited 504,610 times 39 Legal Analyses
Holding that when a party fails to object to a magistrate judge's report and recommendation, our review of the district court's resulting decision is for plain error so long as the party "has been served with notice that [this consequence] will result from a failure to object"
Rule 56 - Summary Judgment
Fed. R. Civ. P. 56 Cited 330,074 times 158 Legal Analyses
Holding a party may move for summary judgment on any part of any claim or defense in the lawsuit
Section 6662 - Imposition of accuracy-related penalty on underpayments
26 U.S.C. § 6662 Cited 6,383 times 66 Legal Analyses
Defining "negligence" as "any failure to make a reasonable attempt to comply with the provisions of this title"
Rule 36 - Requests for Admission
Fed. R. Civ. P. 36 Cited 6,135 times 12 Legal Analyses
Noting that facts admitted pursuant to a Rule 36 discovery request are "conclusively established unless the court, on motion, permits the admission to be withdrawn or amended"
Section 162 - Trade or business expenses
26 U.S.C. § 162 Cited 3,615 times 180 Legal Analyses
Denying deductions for illegal bribes, kickbacks, etc.
Section 401 - Power of court
18 U.S.C. § 401 Cited 2,221 times 10 Legal Analyses
Finding of contempt discretionary in Court
Section 7402 - Jurisdiction of district courts
26 U.S.C. § 7402 Cited 1,625 times 3 Legal Analyses
Granting the district courts jurisdiction over civil actions brought pursuant to § 7403
Section 6700 - Promoting abusive tax shelters, etc
26 U.S.C. § 6700 Cited 362 times 4 Legal Analyses
Criminalizing the making of a statement regarding investment tax benefits that an individual "knows or has reason to kno[w] is false or fraudulent as to any material matter"
Section 6694 - Understatement of taxpayer's liability by tax return preparer
26 U.S.C. § 6694 Cited 288 times 3 Legal Analyses
Understating federal tax liability
Section 7408 - Actions to enjoin specified conduct related to tax shelters and reportable transactions
26 U.S.C. § 7408 Cited 274 times
Providing district courts authority to enjoin persons from engaging in certain "specified conduct" made illegal by the tax laws, including 26 U.S.C. §§ 6700 6701

United States of America v. Renfrow

32 Cited authorities

Holding that a movant's summary judgment motion should be granted "against a [nonmovant] who fails to make a showing sufficient to establish the existence of an element essential to that party's case, and on which that party will bear the burden of proof at trial"

Holding that Federal Water Pollution Control Act did not mandate injunctions against its violation

Holding that the plaintiff's age discrimination claim did not relate back to the originally filed charge of sex discrimination

Holding that a full-time gambler was engaged in a trade or business

Holding that when the factual circumstances are undisputed, whether the facts suffice to demonstrate the existence of a plan as defined by ERISA is a question of law to be reviewed de novo

Holding a control group member liable for withdrawal liability because that entity was a member prior to confirmation as well as after

Finding that admissions by default are an appropriate basis for granting summary judgment

Holding that "the transaction to be analyzed is the one that gave rise to alleged tax benefit" and rejecting taxpayer's argument that economic substance test requires consideration of broader set of transactions

Holding in part that district court erred in reading defendant's binding admissions too broadly

Holding that when a party fails to object to a magistrate judge's report and recommendation, our review of the district court's resulting decision is for plain error so long as the party "has been served with notice that [this consequence] will result from a failure to object"

Holding a party may move for summary judgment on any part of any claim or defense in the lawsuit

Defining "negligence" as "any failure to make a reasonable attempt to comply with the provisions of this title"

Noting that facts admitted pursuant to a Rule 36 discovery request are "conclusively established unless the court, on motion, permits the admission to be withdrawn or amended"

Denying deductions for illegal bribes, kickbacks, etc.

Finding of contempt discretionary in Court

Granting the district courts jurisdiction over civil actions brought pursuant to § 7403

Criminalizing the making of a statement regarding investment tax benefits that an individual "knows or has reason to kno[w] is false or fraudulent as to any material matter"

Understating federal tax liability

Providing district courts authority to enjoin persons from engaging in certain "specified conduct" made illegal by the tax laws, including 26 U.S.C. §§ 6700 6701