Gaylon L. Harrell v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• describing as frivolous the argument that “Congress has no constitutional [taxing] authority over citizens of the states of the United States, as opposed to residents either of the District of Columbia or of U.S. territories and possessions”
• Posner, J. , using State law to decide quiet title actions against Internal Revenue Service
• “[A] plaintiff cannot amend [her] complaint by a brief that [she] files in the . . . court of appeals.”
• “The court may not ... take into account additional facts asserted in a memorandum opposing the motion to dismiss, because such memoranda do not constitute pleadings under Rule 7(a).”
• “The plaintiff cannot cure the deficiency by inserting the missing allegation in a document that is not either a complaint or an amendment to a complaint.”
• “The court may not ... take into account additional facts asserted in a memorandum opposing the motion to dismiss, because such memoranda do not constitute pleadings under Rule 7(a).”

Source: CourtListener parenthetical corpus (CC0).