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Louis v. Commissioner
United States Court of Appeals for the Ninth Circuit
170 F.3d 1232 (1999)
- Written by Steven Pacht, JD
Facts
John Louis (plaintiff) was convicted of tax fraud regarding his 1977 and 1978 taxes. The Internal Revenue Service (IRS) subsequently imposed additions to tax (i.e., penalties) for fraud on Louis for 1976, 1977, and 1978. Louis sued the IRS commissioner (defendant) in the United States Tax Court, contending that the penalties violated the Double Jeopardy Clause of the Fifth Amendment to the United States Constitution because they were criminal in nature. Louis further argued that the penalties violated the Excessive Fines Clause of the Eighth Amendment to the Constitution because they were punitive. The Tax Court rejected Louis’s claims. Louis appealed.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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