Weblanguage used by Justice Jackson in Spies v. United States, 317 U.S. 492, 497 (1943), and discussed by the majority in Ki Se Lee, 368 F.3d at 224, as relevant only in the context of violations of the Revenue Act of 1936. Spies has not been interpreted so narrowly. See Boulware v. United States, 128 S. Ct. 1168, 1173 WebMichael Boulware (defendant) was the founder, president, and controlling shareholder of Hawaiian Isles Enterprises (HIE), a closely held corporation. Boulware was accused by …
Boulware v. United States - Opposition OSG Department of Justice
WebIn Boulware v. United States, 128 S.Ct. 1168 (2008), the Supreme Court held that a diverter of corporate funds facing charges of criminal tax evasion may claim return-of-capital treatment under 26 U.S.C. § 301 wit hout pr oducing evidence that either he or the corporation intended a return of capital when the diversion occurred. WebSep 20, 2004 · See, e.g., United States v. Luther, 481 F.2d 429, 433 (9th Cir.1973); United States v. Popkin, 623 F.2d 108, 110 (9th Cir.1980). Even assuming that Michael Boulware's interpretation is correct, Michael Boulware has failed to show that the requested documents are irrelevant to the underlying tax investigation of Hawaiian Isles. cnn rightward shift
Boulware v. Commissioner, No. 14-1147 (D.C. Cir. 2016) :: Justia
WebOct 21, 2014 · MICHAEL H. BOULWARE, PETITIONER v. UNITED STATES OF AMERICA ON PETITION FOR A WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT BRIEF FOR THE UNITED STATES IN OPPOSITION OPINIONS BELOW The opinions of the court of appeals (Pet. App. 1-14, 27-61) are … WebWhen a corporation makes a distribution to a stockholder initially characterized as a “distribution,” that “distribution” may subsequently be legitimately characterized as a non-taxable “return of capital” if the corporation has no earnings. Boulware v. United States, 552 U.S. 421, 430-31 (2008). The tax return must have been filed. WebSee United States v. Boulware, 558 F.3d 971 (9th Cir. 2009). Boulware is the president and sole owner of two companies, Hawaiian Isle Enterprises, Inc. and HIE Holdings, Inc., which paid his legal and professional fees in the criminal trial … cnn right wing shift