United States v. Ralph Lockyer

How courts have described this case

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

• explaining that the directive did not fall under Accardi because “[t]he entire design and thrust . . . is that of internal administration”
• defendant taxpayer cannot take advantage of provision in Internal Revenue Audit Technique Handbook and Internal Revenue Manual instructing when revenue agent must suspend investigation on finding an indication of fraud
• defendant taxpayer cannot take advantage of provision in Internal Revenue Audit Technique Handbook and Internal Revenue Manual instructing when revenue agent must suspend investigation on finding an indication of fraud
• Leahey does not apply to rule not published as definition of taxpayers' rights
• Violations of internal IRS regulations did not involve procedural due process rights.

Source: CourtListener parenthetical corpus (CC0).