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Laing Vs. United States
Cites for this judgment
- US Supreme Court
- Jan 13, 1976
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Laing v. UnitedSearch
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States - 423 U.S. 161 (1976) U.S. Supreme Court Laing v. UnitedSearch
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States, 423 U.S. 161 (1976) Laing v. UnitedSearch
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et seq. We reverse in No. 73-1808 and affirm in No. 74-75. I A. No. 73-1808, Laing v. UnitedSearch
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The District Court, relying on its controlling court's decision in Irving v. GraySearch
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affirmed per curiam. 496 F.2d 853 (1974). It expressly declined to follow the Sixth Circuit's decision in Rambo v. UnitedSearch
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These rulings of the Second Circuit, and one of the Page 423 U. S. 167 Seventh Circuit, Williamson v. UnitedSearch
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States, 31 A.F.T.R.2d 73-800 (1971), appeared to be in conflict with holdings by other Courts of Appeals, Rambo v. UnitedSearch
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Hall v. UnitedSearch
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and Clark v. CampbellSearch
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U.S. 824 (1974). B. No. 74-75, United States v. HallSearch
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IRS from selling the automobile and from seizing any more of respondent's property. Thereafter, relying upon Schreck v. UnitedSearch
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for the Sixth Circuit affirmed per curiam, 493 F.2d 1211 (1974), relying upon its opinion and decision in Rambo v. UnitedSearch
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termination, the taxpayer's taxable year has come to a close. See Sanzogmo v. CommissionerSearch
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assessment for a nonterminated year, but denying it to those subjected to an assessment following a jeopardy termination. v. BasedSearch
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Together with No. 74-75, United States et al. v. HallSearch
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United States v. ClarkSearch
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The developing conflict among the federal courts was recognized in Willits v. RichardsonSearch
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F.2d 240, 246 n. 4 (CA5 1974), and Jones v. CommissionerSearch
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contained its own assessment authority, see Schreck v. UnitedSearch
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States, 301 F.Supp. 1265 (Md.1969), but it has since abandoned that position, see Lisner v. McCanlessSearch
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The broad dictum to the contrary in the Board of Tax Appeals' 1938 opinion in Ludwig Littauer & Co. v. CommissionerSearch
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case, Jones v. CommissionerSearch
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be denied access to a judicial forum for up to six months. See supra at 423 U. S. 173 . Cf. Phillips v. CommissionerSearch
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the Government must make some preliminary showing in support of the assessment. See North Georgia Finishing, Inc. v. Di-ChemSearch
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U. S. 371 , 401 U. S. 379 (1971) (emphasis in original). See, e.g., Bell v. BursonSearch
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attributes of the due process requirement, however, depend upon accommodating the competing interests involved. Goss v. LopezSearch
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law denies an affected taxpayer access to any forum for review of jeopardy assessments for up to 60 days. In Goss v. LopezSearch
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North Georgia Finishing, Inc. v. Di-ChemSearch
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from other deprivations for due process purposes. I am aware of no precedent drawing that distinction. Phillips v. CommissionerSearch
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Flora v. UnitedSearch
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States, 362 U. S. 145 , 362 U. S. 176 (1960). See Helvering v. MitchellSearch
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power with respect to the collection of taxes, the Government's very existence could be threatened. See Cheatham v. UnitedSearch
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Bob Jones University v. SimonSearch
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the taxpayer, such as a person claiming a prior lien, and have no possible application here. See Bob Jones University v. SimonSearch
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U.S. at 416 U. S. 731 -732, n. 6. The third exception is of judicial origin. The Court, in Enochs v. WilliamsSearch
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no adequate legal remedy. The Court recently reaffirmed the Williams Packing exception in Bob Jones University v. SimonSearch
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It noted that a somewhat different attitude had been evident in the 1930's. See Miller v. StandardSearch
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Nut Margarine Co., 284 U. S. 498 (1932), and Allen v. RegentsSearch
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during the taxable year, rather than after its close and a return for it has been filed. See Ludwig Littauer .& Co. v. CommissionerSearch
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had not yet appeared. Thus, I disagree with the suggestions contained in Clark v. CampbellSearch
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F.2d 108, 121 (CA5 1974), in Rambo v. UnitedSearch
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