This case concerned Amax Coal Company's challenge to Black Lung Excise Taxes assessed under 26 U.S.C. § 4121 on coal sold from its mines, specifically whether the taxable weight included excess surface moisture acquired during mining and washing. The court reviewed the history of the Black Lung Benefits program and the statute's imposition of tax per ton of coal, noting that prior precedent in A.J. Taft Coal Co. v. United States had interpreted 'coal' to exclude excess moisture beyond inherent levels. Following IRS Rev. Rul. 86-96, the court determined that producers may reduce taxable weight for excess moisture if supported by competent evidence demonstrating its existence and amount. The opinion sets forth findings of fact on coal composition, moisture sources, and industry practices to support application of this exclusion to Amax's operations.
In Greco v. Ford Motor Co., plaintiffs sued Ford after sustaining injuries in a 1992 rollover accident involving their 1989 Bronco II on an interstate highway, alleging the vehicle lacked adequate lateral stability as a design defect. Ford moved for summary judgment on the products liability claims and on the request for punitive damages, arguing that plaintiffs' loss of the vehicle after the accident constituted spoliation of evidence warranting dismissal and that there was insufficient evidence of willful or wanton conduct to support punitives. The court denied all motions, finding that plaintiffs did not act in bad faith in surrendering the totaled vehicle to their insurer and that genuine issues of material fact existed regarding both the underlying defect claims and whether Ford's conduct justified punitive damages under Indiana law. The court noted that expert testimony created factual disputes best resolved at trial rather than on summary judgment.
This case involves the National Labor Relations Board seeking court enforcement of a subpoena duces tecum against The Evansville Courier Co., a newspaper, to obtain the identities of entities that placed help-wanted ads for electricians. The Union had filed charges alleging that its members were denied employment due to union affiliation, and the Board needed the advertiser information to investigate. After the newspaper refused to comply voluntarily or via the Board's process, including a denied petition to quash, the district court adopted the magistrate judge's report and recommendation. The court ordered the respondent to produce the subpoenaed information within ten days, relying on the Board's statutory authority under the National Labor Relations Act to issue subpoenas and the limited scope of judicial review for such administrative enforcement actions.
This case involved whether debtor David Wayne Smith's unpaid federal income taxes from 1984-1989 could be discharged in bankruptcy under 11 U.S.C. § 523(a)(1)(C). Smith had filed accurate tax returns but submitted false W-4 forms claiming excessive exemptions to reduce withholding from his wages, which he admitted doing to increase his spendable income. The bankruptcy court found the debt dischargeable after applying a criminal standard of willfulness that requires bad purpose or evil motive. The district court reversed and remanded, holding that the civil standard applies instead, which requires only a voluntary, conscious, and intentional violation of a known legal duty.
In this case, plaintiff Robert U. Carpenter sued the IRS under the Privacy Act, 5 U.S.C. § 552a, seeking disclosure of supporting documents such as accounting assessment journals and registers related to specific Form 23-C assessment certificates that pertained to his tax liabilities. The IRS moved for summary judgment, arguing that the requested materials were not maintained in a "system of records" retrievable by individual name or identifier. The court granted the motion, holding that the Privacy Act's access provisions did not apply because the Forms 23C contain only aggregate totals without taxpayer-specific identifiers and are not part of any system of records from which information can be retrieved by the individual's name or other identifying particular. The court relied on the declaration of an IRS disclosure specialist confirming that the documents are not accessible in this manner and noted that Carpenter did not dispute these facts, only their legal significance under the statute and regulations.
The case Amax Coal Co. v. United States involved a coal company's claim for a refund of Black Lung Excise Taxes paid to the IRS from 1989 to 1991, challenging the IRS's refusal to allow any percentage exclusion for excess moisture in coal sold for less than $13.05 per ton from the Belle Ayr and Eagle Butte mines. AMAX filed quarterly returns, underwent an audit that assessed additional taxes, paid them, and sought refunds that the IRS denied. Both parties moved for partial summary judgment on whether excess moisture could be excluded from the tax base under the relevant contracts and regulations. The court denied both motions, holding that genuine issues of material fact remained as to whether the base price per ton already accounted for expected excess moisture content in a way that would affect the proper tax computation.
