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Lefcourt v. United States

125 F.3d 79 (1997)

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Lefcourt v. United States

United States Court of Appeals for the Second Circuit

125 F.3d 79 (1997)

Facts

Gerald B. Lefcourt, P.C. (Lefcourt) (plaintiff) was a criminal-defense law firm. Lefcourt was retained by a client who paid Lefcourt more than $10,000 in cash for legal services. Lefcourt submitted Form 8300 to the Internal Revenue Service (IRS), stating that the firm had received more than $10,000 on a particular date, but omitted the name of the client because revealing it would prejudice the client and the information was protected by the Fifth and Sixth Amendments and the Lawyers’ Code of Professional Responsibility. The IRS assessed Lefcourt a penalty based on the intentional disregard of the reporting requirements of Internal Revenue Code (I.R.C.) § 6050I. Lefcourt paid the penalty and claimed a refund for the same amount. Lefcourt brought a refund action against the government (defendant). Lefcourt and the government both moved for summary judgment. The district court granted the government’s motion and denied Lefcourt’s motion, finding that Lefcourt intentionally disregarded the filing requirement of § 6050I because it knew § 6050I’s requirements and voluntarily, consciously, and intentionally failed to comply. Lefcourt appealed, arguing that intentional disregard cannot be established if one has a good-faith belief in the legality of one’s conduct, even if that belief is mistaken or unreasonable.

Rule of Law

Issue

Holding and Reasoning (Walker, J.)

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