Fraser v. Commissioner of Internal Revenue Service
Cases that cite this one
21 later published cases cite this decision.
- Mishawaka Properties Co. v. Commissioner (United States Tax Court 1993)
- Luisa Anne Forschler v. Commissioner of Internal Revenue, Luisa Anne Forschler v. Commissioner of Internal Revenue (9th Cir. 1996)
- Finkelman v. Commissioner (United States Tax Court 1994)
- Regents Park Partners (United States Tax Court 1992)
- Day v. Sears Holdings Corp. (United States District Court for the Central District of California 2013)
- Multi-Pak Corp. v. Comm'r (United States Tax Court 2010)
- Booth-El v. Nuth (District Court, D. Maryland 2001)
- Lawrence P. Crnkovich v. United States (Fed. Cir. 2000)
- Crnkovich v. United States (Fed. Cir. 2000)
- Crnkovich v. United States (United States Court of Federal Claims 1998)
- Bartlett v. Commissioner (United States Tax Court 1997)
- Dharma Enters. v. Commissioner (United States Tax Court 1997)
- Bergstrom v. United States (United States Court of Federal Claims 1996)
- Fenning v. Glenfed, Inc. (Cal. Ct. App. 1995)
- Estate of McCormick v. Commissioner (United States Tax Court 1995)
- Federal Deposit Insurance v. Gonzalez-Gorrondona (United States District Court for the Southern District of Florida 1993)
- People Ex Rel. Sepulveda v. Highland Federal Savings & Loan (Cal. Ct. App. 1993)
- Estate of Cohn v. Commissioner (United States Tax Court 1993)
- Federal Deposit Insurance Corporation, as Receiver for Central Savings and Loan Association v. Daniel T. McSweeney Frederick C. Stalder (9th Cir. 1992)
- In re Sunrise Securities Litigation (District Court, E.D. Pennsylvania 1992)
- WOLVERINE, LTD. v. COMMISSIONER (United States Tax Court 1992)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion
Unpublished Disposition
NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel.
John K. FRASER, Plaintiff-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE SERVICE, Defendant-Appellee.
John K. FRASER, Plaintiff-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE SERVICE, Defendant-Appellee.
Nos. 90-15195, 90-15616
United States Court of Appeals, Ninth Circuit.
Submitted May 2, 1991.*
Decided June 28, 1991.
Before KILKENNY, SNEED and FERGUSON, Circuit Judges.
MEMORANDUM**
Fraser appeals from the district court's dismissal of his complaint challenging the Internal Revenue Service's assessment and collection of unpaid personal income taxes. We affirm.
With respect to Fraser's damage claims, we find no error in the district court's conclusion that the government was entitled to immunity. See 28 U.S.C. Sec. 2680(c); Morris v. United States, 521 F.2d 872, 874 (CA9 1975). As for Fraser's quiet title claim, he may not use the procedural vehicle provided by 28 U.S.C. Sec. 2410 to collaterally attack the merits of his assessment. See Elias v. Connett, 908 F.2d 521, 527 (CA9 1990). Finally, the government's effectively unopposed documentation concerning its alleged failure to comply with the various notice provisions of, e.g., 26 U.S.C. Secs. 6212 and 6213, support the district court's conclusion that Fraser's claims were barred by the Anti-Injunction Act, 26 U.S.C. Sec. 7421(a). Cf. Church of Scientology of California v. United States, 920 F.2d 1481, 1485-86 (CA9 1990), cert. denied, 59 U.S.L.W. 3674 (U.S. June 3, 1991) (No. 90-1467).
AFFIRMED.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.