(DOWNLOAD) "Robinson v. U.S" by United States Court of Appeals for the Third Circuit * Book PDF Kindle ePub Free
eBook details
- Title: Robinson v. U.S
- Author : United States Court of Appeals for the Third Circuit
- Release Date : January 21, 1990
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 58 KB
Description
WEIS, Circuit Judge Opinion OF THE COURT Asserting a procedural defect, taxpayers challenged an Internal Revenue Service lien via a suit under 28 U.S.C. § 2410(a). The district court dismissed for lack of jurisdiction concluding that the taxpayers' attack necessarily struck at the underlying assessment, a result it believed was barred by this Court's precedent. We reverse. Our prohibition against assaults on the ""merits of an assessment"" applies to the amount of tax due and does not prevent scrutiny of procedural lapses by the IRS. In 1971 the Internal Revenue Service assessed plaintiffs for unpaid income taxes for the years 1968 and 1969. Because of taxes assertedly due for those years, the IRS filed liens in Montgomery County, Pennsylvania against the home that plaintiffs own.
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