332 U.S. 380 (1947) Cited 1,073 times 2 Legal Analyses
Holding that insured must strictly comply with all terms and conditions of federal insurance policy and recognizing duty of courts to observe conditions defined by Congress for charging the public treasury
Holding that an intra-family transfer of property for little to no consideration supported a finding that the debtor willfully attempted to evade payment of taxes
Holding that a debtor's "belated acceptance of responsibility" by entering into a post-assessment settlement with the IRS and agreeing to make installment payments on his acknowledged tax liability did not "constitute an honest and reasonable attempt to comply with the requirements of the tax law," where the debtor had "made every attempt to avoid paying his taxes until the IRS left him with no other choice"
Considering outside materials for certain 12(b) arguments, thereby converting the motion to one for summary judgment with respect to particular counts, and excluding the materials from other 12(b) arguments, treating the arguments regarding those counts as a motion to dismiss
Finding that a settlement officer did not err when he retained an offer-in-compromise down payment as a "collection alternative" and applied the amount to the petitioner's outstanding liabilities
26 U.S.C. § 7433 Cited 1,112 times 3 Legal Analyses
Creating a cause of action for damages against the United States "[i]f, in connection with any collection of Federal tax with respect to a taxpayer, any officer or employee of the Internal Revenue Service recklessly or intentionally, or by reason of negligence, disregards any provision of this title, or any regulation promulgated under this title"
Stating that interest on tax underpayments "shall be assessed, collected, and paid in the same manner as taxes" and that any reference "to any tax imposed by this title shall be deemed also to refer to interest imposed by this section on such tax"