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United States Vs. Stuart
Cites for this judgment
- US Supreme Court
- Feb 28, 1989
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U.S. 353 (1989) U.S. Supreme Court United States v. StuartSearch
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U.S. 353 (1989) United States v. StuartSearch
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So long as the IRS satisfies Page 489 U. S. 354 the requirements of good faith set forth in United States v. PowellSearch
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summons, the IRS' affidavits plainly satisfied the requirements of good faith set forth in United States v. PowellSearch
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with a view to criminal prosecution outside the United States. The elements of good faith outlined in United States v. PowellSearch
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Page 489 U. S. 355 supra, do not constitute such a restriction, nor does the reasoning in United States v. LaSalleSearch
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long as the summons meets statutory requirements and is issued in good faith, as we defined that term in United States v. PowellSearch
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in good faith. The Court of Appeals further stated that the elements of good faith we described in United States v. PowellSearch
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rather, in light of our subsequent decision in United States v. LaSalleSearch
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Brief any citation in this list with AI Studio
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resolve a conflict between the Ninth Circuit's decision in this case and the Second Circuit's holding in United States v. ManufacturersSearch
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Traders Trust Co., 703 F.2d 47 (1983). We now reverse. II A In United States v. PowellSearch
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Id. at 379 U. S. 58 . See also United States v. BiscegliaSearch
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of good faith we set forth in Powell and have repeatedly reaffirmed. See, e.g., Tiffany Fine Arts, Inc. v. UnitedSearch
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c) supports this conclusion. Prior to its enactment, we held in United States v. LaSalleSearch
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U. S. 176 , 457 U. S. 180 (1982), quoting Maximov v. UnitedSearch
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with a view to criminal prosecution outside the United States. The elements of good faith we outlined in United States v. PowellSearch
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U. S. 48 (1964), do not contain such a restriction. Nor does our reasoning in United States v. LaSalleSearch
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Bacardi Corp. of America v. DomenechSearch
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since their conduct generally evinces their understanding of the agreement they signed. See Trans World Airlines, Inc. v. FranklinSearch
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Factor v. LaubenheimerSearch
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Sumitomo, 457 U.S. at 457 U. S. 184 -185. See also Kolovrat v. OregonSearch
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under the 1942 Convention. So long as the IRS itself acts in good faith, as that term was explicated in United States v. PowellSearch
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Supp. 1 1985). See also McKibbon v. QueenSearch
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of grand juries in Canada). Other common law countries have eliminated the grand jury as well. See, e.g., Saywell v. Attorney-GeneralSearch
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Scheim & Cantillon Ross, Stuart v. UnitedSearch
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said in the earlier case that the Court cites as authority for its approach. In Sumitomo Shoji America, Inc. v. AvaglianoSearch
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their obvious meaning effects a result inconsistent with the intent or expectations of its signatories.' . . . Maximov v. UnitedSearch
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Maximov v. UnitedSearch
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Rainbow Navigation, Inc. v. DepartmentSearch
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construction is that an agreement's language is the best evidence of its purpose and its parties' intent. In Rocca v. ThompsonSearch
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ambiguous have we found it appropriate to give authoritative effect to extratextual materials. See, e.g., Air France v. SaksSearch
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New York Indians v. UnitedSearch
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they become part of the treaty and of the law of the United States, see Northwestern Bands of Shoshone Indians v. UnitedSearch
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or amend it as a matter of internal law by simply enacting inconsistent legislation. La Abra Silver Mining Co. v. UnitedSearch
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for the District of Columbia, in successive phases of the same controversy, last May, see Rainbow Navigation, Inc. v. DepartmentSearch
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of Navy, 686 F.Supp. 354 (1988), and last November, see Rainbow Navigation, Inc. v. DepartmentSearch
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U.S. Supreme Court United States v. StuartSearch
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United States v. LaSalleSearch
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United States v. ManufacturersSearch
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II A In United States v. PowellSearch
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Tiffany Fine Arts, Inc. v. UnitedSearch
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See Trans World Airlines, Inc. v. FranklinSearch
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McKibbon v. QueenSearch
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Saywell v. Attorney-GeneralSearch
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