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314 U.S. 441, 62 S.Ct. 303, 86 L.Ed. 329
(Cite as: 314 U.S. 441, 62 S.Ct. 303)
simply because he does not maintain a domestic Under the District of Columbia statute imposing
establishment at his former place of abode. D.C.Code an income tax on every individual domiciled in the
Supp. V, T. 20, § 980a(a). District on the last day of the taxable year, the
question of domicile is a question of fact to be settled
[5] District of Columbia 132 33(11) only by a realistic and conscientious review of the
many relevant indicia of where a man's home is, and
according to the established modes of proof.
132 District of Columbia
D.C.Code Supp. V, T. 20, § 980a(a).
132k33 Taxation
132k33(10) Income Taxes
132k33(11) k. Domicile of Taxpayer. Most [8] Domicile 135 1
Cited Cases
(Formerly 132k33) 135 Domicile
135k1 k. Nature and Elements. Most Cited Cases
Persons who live in the District of Columbia,
and have no fixed and definite intent to return and The place where a man lives is properly taken to
make their homes where they were formerly be his “domicile” until facts adduced establish the
domiciled, acquire a “domicile” in the District within contrary.
statute imposing an income tax on every individual
domiciled in the District on the last day of the taxable [9] District of Columbia 132 33(11)
year, and, to keep from acquiring a domicile in the
District, the intention to return must be fixed, though
132 District of Columbia
the date need not be, and must be unconditional,
132k33 Taxation
though the time may be contingent. D.C.Code Supp.
132k33(10) Income Taxes
V, T. 20, § 980a(a).
132k33(11) k. Domicile of Taxpayer. Most
Cited Cases
[6] District of Columbia 132 33(11) (Formerly 132k33)
in the service of the government is of great differ somewhat in facts, but each involves a
significance, the manner of living in the District, controversy as to whether respondent was domiciled
taken in consideration with the person's station in life, within the District of Columbia on December 31,
and all facts which go to show the relations retained 1939, within the meaning of Sec. 2(a) of the District
to the former place of abode are relevant, and the of Columbia Income Tax Act, FN1 which lays a tax on
question whether taxes similar in character to those ‘the taxable income of every individual domiciled in
laid by the statute have been paid elsewhere should the District of Columbia on the last day of the taxable
also be considered. D.C.Code Supp. V, T. 20, § year.’ The following facts appear from proceedings
980a(a). before the Board of Tax Appeals for the District of
Columbia:
[16] Courts 106 96(1)
FN1 53 Stat. 1087; 20 D.C.Code (Supp. V,
106 Courts 1939) s 980a(a).
106II Establishment, Organization, and Procedure
106II(G) Rules of Decision The respondent in No. 58, a single man, first
106k88 Previous Decisions as Controlling came to the District of Columbia in 1935 to work as
or as Precedents an economist in the Treasury Department, and was
106k96 Decisions of United States blanketed into Civil Service in that position in July,
Courts as Authority in Other United States Courts 1938. He came here from Detroit, Michigan, and has
106k96(1) k. In General. Most Cited ever since continued to *446 be a registered voter and
Cases has voted in the elections and primaries in Wayne
County, Michigan. He was born in New London,
Whether a Treasury Department employee who Connecticut, in 1905, and when five years old moved
maintained his status as a registered voter in with his parents to Los Angeles, California where he
Michigan and voted in elections and primaries there, resided until 1926. when he removed to Berkeley,
and a chief clerk of the Personnel and Organization California. His parents live in California. In 1929 he
Division of the National Guard Bureau with offices completed his studies at Brown University and
in Washington who was born and reared in immediately thereafter accepted employment in a
Pennsylvania and paid poll and occupational taxes trust company in Detroit, Michigan, of which one of
and voted in Pennsylvania, were domiciled in the his former professors at Brown was vice president.
District of Columbia within statute imposing an While in Detroit, respondent lived first in a rooming
income tax on every individual domiciled in the house and later in an apartment. He owns no property
District on the last day of the taxable year, presented there. In the District of Columbia he lives in an
“questions of fact” to be settled by the Board of Tax apartment, which he has furnished himself. His
Appeals for the District, and did not call for rulings present employment pays him $6,500 a year, while
of nontaxability as a matter of law because of a that which he left in Detroit paid but $6,000. He
decision of the United States Court of Appeals for the testified before the Board of Tax Appeals that he
District of Columbia. D.C.Code Supp. V, T. 20, § does not think he would improve his condition by
980 a(a). returning to Detroit, but that ‘It is the place to which I
will return if I ever become disemployed by the
Government, which I hope will not happen * * *.’
**305 *442 Messrs. Glenn Simmon, Richmond B.
Although he has no present connection with the trust
Keech, and Vernon E. West, all of Washington, D.C.,
company, he believes that he could go back with it if
for petitioner.
he should return to Detroit. If a better position than
he now has should be offered in a city other than
*444 Mr. Harry R. Turkel, of Washington, D.C., for Detroit, he ‘very likely would’ accept it, despite a
respondents. ‘preference for Detroit’ based on a belief that he
‘would fit in more easily’ there.
*445 Mr. Justice JACKSON delivered the opinion of
the Court. Respondent claimed that Detroit was his ‘legal
These cases, which have been argued together, residence’ and that he was not domiciled in the
District of Columbia. The Board of Tax Appeals for is a contributor to Washington charities, a member of
the District of Columbia found ‘as a fact’ that when the Motor Club of Washington, and of the
he came to Washington in 1935 he ‘had an intention Washington units of ‘Tall Cedars of Lebanon’ and
to remain and make his home in the District of the ‘Mystic Shrine,’ both identified with
Columbia for an indefinite period of time; and that freemasonry. He has filed his federal income-tax
such intention has ever since, and still does remain returns with the Collector of Internal Revenue at
with him; and that if he has any intention to return Baltimore, and always paid to the District of
and make his home in Detroit, it is a floating Columbia an intangible property tax while that tax
intention.’ The Board held, however, ‘as *447 matter was in effect.
of law,’ that on December 31, 1939, the last day of
the taxable year, petitioner was not domiciled in the Respondent had resided in Pennsylvania from
District of Columbia, believing that it was compelled birth until he left for Washington. He claimed as his
to do so by the decision of the United States Court of ‘legal residence’ the residence of his parents in
Appeals for the District of Columbia in Harrisburg, where they still keep intact his room in
**306Sweeney v. District of Columbia, 72 App.D.C. which are kept some of his clothes and childhood
30, 113 F.2d 25, 129 A.L.R. 1370, certiorari denied, toys. Though paying nothing as rent or for lodging,
310 U.S. 631, 60 S.Ct. 1082, 84 L.Ed. 1402. he has from time to time made presents of money to
his parents. He has visited his parents' home in
The respondent in No. 59 lived in the District of Harrisburg over week ends at least eight times a year,
Columbia for twenty-six years after coming here and has been there annually between Christmas and
from Pennsylvania in 1914 to accept a clerical the New Year. A registered voter in Pennsylvania, he
position of indefinite tenure under Civil Service in has voted in all its general elections since he became
the Patent Office. He was then on a year's leave of of age. He paid the Pennsylvania poll tax until it was
absence from a railroad by which he was employed, superseded by an occupational tax, which he has also
but continued in the Civil Service to the time of paid. Payment of such taxes was a prerequisite to
hearing, becoming Chief Clerk of the Personnel and voting.
Organization Division of the National Guard Bureau,
War Department, with offices in Washington. Single In 1912 respondent became a life member of the
when he came, in 1917 he married a native of Robert Burns Lodge No. 464, Free and Accepted
Washington, who died in 1935 without children. Masons, and of the Harrisburg Consistory, Scottish
Shortly after their marriage the couple purchased as a Rite, both Masonic bodies. While he resided in
home, premises at 1426 Massachusetts Avenue, S.E., Harrisburg he was a member of the Bible Class of the
in the District of Columbia, in which respondent still Pine Street Presbyterian Church, which he still
lives. In about 1925, he purchased a lot at ‘Selby on attends on visits there, and to which he made
the Bay’ in nearby Maryland, and before his wife's substantial contributions in 1939. He owns jointly
death he bought a building lot in the District of with his father a note secured by a mortgage on
Columbia, acting on his wife's pleas for a summer Pennsylvania real estate. Respondent testified that he
place and a better residence. He agreed with his wife expected to retire from Civil Service in four years
that on his retirement six months would be spent at and intended then to sell his house and ‘leave
Selby. He testified that he never desired to purchase Washington.’
the lot in the District of Columbia, but did so at the
insistence of his wife. He put a ‘For Sale’ sign on it The Board found ‘as a fact’ that at the end of one
when she died, and both lots, which he still owns, are year after he came to the District in 1914 respondent
up for sale. He has deposits in three Washington ‘had an *449 intention to remain and make his home
financial institutions and owns first trust notes on in the District of Columbia for an indefinite period of
property located in Maryland and Virginia. time and that intention remained with him, at least
until the death of his wife.’ As in No. 58, it
In 1915 respondent became a member of a considered itself bound by the Sweeney case, supra,
Lutheran church in Washington, and has ever since and accordingly held ‘as a matter of law’ that the
been an active member, at one time serving as petitioner was not domiciled in the District on
president of its Christian *448 Endeavor Society. He December 31, 1939, and never had been.
definition read: ‘Domicile is the place where one has Some enter the Civil Service, finding tenure and pay
his true, fixed, permanent home and principal there more secure than in private enterprise. Political
establishment**308 and to which, whenever he is ties are of no consequence in obtaining or
absent, he has the intention of returning, and where maintaining their positions. At the other entreme are
he exercises his political rights.FN3 * * * There must those who hold appointive office at the pleasure of
exist in combination the fact of residence and animus the appointing officer. These latter, as well as
manendi-’ which means residence and his intention to appointive officers with definite but unprotected
return (sic); so that under this definition he could tenure, and all elective officers, usually owe their
certainly live in the District of Columbia and have his presence here to the intimate and influential part they
legal domicile in any other State in the United States.' have played in community life in one of the States.
84 Cong.Rec. 8974.
Relatively few persons here in any branch of the
FN3 Exercise of political rights elsewhere Government service can truthfully and accurately lay
cannot be considered as meant to be claim to an intention to sever themselves from the
conclusive on the issue of taxability in the service on any exact date. Persons in all branches
District. See statement by Representative usually desire, quite naturally and properly, to
Dirksen on the floor of the House. Ibid. continue family life and to have the comforts of a
domestic establishment for whatever may be the term
Representative Bates, another of the House of their stay here. This is true of *453 many Senators
conferees, stated in response to a question regarding and Congressmen, cited by Senator Overton as
the possibility of triple taxation, ‘We raised that typical of those whom the limitation of the statute to
particular point (in conference) because we are much persons ‘domiciled’ here ‘necessarily excludes.’
concerned about how those who come from our
States would be affected by the income-tax Turning to the judicial precedents for further
provisions of the new law, and it was distinctly *452 guidance in construing ‘domicile’ as used in the
understood that in this bill there should be no triple statute, we find it generally recognized that one who
taxation * * *.’ 84 Cong.Rec. 8973. comes to Washington to enter the Government
service and to live here for its duration does not
The unusual character of the National Gapital, thereby acquire a new domicile. More than a century
making the income tax a ‘very explosive and ago, Justice Parker of New Hampshire observed that
controversial item,'FN4 was vividly before the ‘It has generally been considered that persons
Congress, and must also be considered in construing appointed to public office under the authority of the
the statute imposing the tax. United States, and taking up their residence in
Washington for the purpose of executing the duties of
FN4 84 Cong.Rec. 8972. such office, do not thereby, while engaged in the
service of the government, lose their domicil in the
place where they before resided, unless they intend
The District of Columbia is an exceptional on removing there to make Washington their
community. It is not a local municipal authority, but permanentFN5 residence.’ See Atherton v. Thornton, 8
was established under the Constitution as the seat of N.H. 178, 180. By and large, subsequent cases have
the National Government. Those in Government taken a like view.FN6 It should also be observed *454
service here are not engaged in local enterprise, that a policy **309 against loss of domicile by
although their service may be localized. Their work is sojourn in Washington is expressed in the
that of the nation, and their pay comes not from local constitutions and statutes of many states. FN7 Of
sources but from the whole country. Because of its course no individual case, constitution, or statute is
character as a federal city, there is no local political controlling, but the general trend of these authorities
constituency with whose activities those living in it is a significant recognition that the distinctive
may identify themselves as a symbol of their character of Washington habitation for federal
acceptance of a local domicile. service is meaningful to those who are served as well
as to those in the service.
Not all who flock here are birds of a feather.
Business Costs, 49 Harv.L.Rev. 593, 596; 1 but is subject to the infirmity of any self-serving
Beale, Conflict of Laws, s 19.1. declaration, and may frequently lack persuasiveness
or even be contradicted or negatived by other
[8][9] The place where a man lives is properly declarations and inconsistent acts.
taken to be his domicile until facts **310 adduced
establish the contrary. Ennis v. Smith, 14 How. 400, [14] Whether or not one votes where he claims
423, 14 L.Ed. 472; Anderson v. Watt, 138 U.S. 694, domicile is highly relevant but by no means
706, 11 S.Ct. 449, 452, 34 L.Ed. 1078. The taxing controlling.FN11 Each state prescribes for itself the
authority is warranted in treating as prima facie qualifications of its voters, and each has its own
taxable any person quartered in the District on tax machinery for determining compliance with such
day whose status it deems doubtful. It is not an qualifications. A vote cast without challenge and
unreasonable burden upon the individual, who knows adjudication may indicate only laxity of the *457
best whence he came, what he left behind, and his state officials, and even an adjudication of the right to
own attitudes, to require him to establish domicile vote cannot preclude the levy of a tax by an arm of
elsewhere if he is to escape the tax. the Federal Government. On the other hand, failure to
vote elsewhere is, of course, not conclusive that
[10] To hold taxable one who contends that he is domicile is here.
not domiciled here, the Board need not find the exact
time when the ‘attitude and relationship of person to FN11 See statements of Representative
place’ which constitute domicile, Texas v. Florida, Dirksen, 84 Cong.Rec. 8973.
306 U.S. 398, 411, 59 S.Ct. 563, 570, 830, 83 L.Ed.
817, 121 A.L.R. 1179, were *456 formed, so long as [15] Also of great significance is the nature of
it finds they were formed before the tax day. What the position which brings one to or keeps him in the
was at first a firm intent to return may have withered service of the Government: whether continuous or
gradually in consequence of dissolving associations emergency, special or war-time in character; whether
elsewhere and growing interests in the District. It is requiring fixed residence in the District or only
common experience that this process usually is intermittent stays; whether entailing monetary
unmarked by any dramatic or even sharply defined sacrifices or betterment; and whether political or non-
episode. The taxing authority need not find just when political. Those dependent upon the action of a local
the intent was finally dissipated; it is enough that it constituency on the first Tuesday after the first
finds that this has happened before the tax day. Monday in November are of course loath to leave
their local identifications behind when taking up
[11] If one has at any time become domiciled Government duties in Washington.
here, it is his burden to establish any change of status
upon which he relies to escape the tax. Anderson v. Of course the manner of living here, taken in
Watt, supra, 138 U.S. at page 706, 11 S.Ct. at page connection with one's station in life, is relevant. Did
452, 34 L.Ed. 1078. he hire a furnished room or establish himself by the
purchase of a house? Or did he rent a house or
[12] In order to retain his former domicile, one apartment? Has he brought his family and
who comes to the District to enter Government dependents here? Has he brought his goods? What
service must always have a fixed and definite intent relations has he to churches, clubs, lodges, and
to return and take up his home there when separated investments that identify him with the District?
from the service. A mere sentimental attachment will
not hold the old domicile. And residence in the All facts which go to show the relations retained
District with a nearly equal readiness to go back to one's former place of abode are relevant in
where one came from or to any other community determining domicile. What bridges have been kept
offering advantages upon the termination of service is and what have been burned? Does he retain a place
not enough. of abode there, or is there a family home with which
he retains identity? Does he have investments in
[13] One's testimony with regard to his intention local property or enterprise which **311 attach him
is of course to be given full and fair consideration, to the community? What are his affiliations with the
Reversed.
U.S. 1941.
District of Columbia v. Murphy
314 U.S. 441, 62 S.Ct. 303, 86 L.Ed. 329
KEYCITE
District of Columbia v. Murphy, 314 U.S. 441, 62 S.Ct. 303, 86 L.Ed. 329 (U.S.Dist.Col.,
Dec 15, 1941) (NO. 58, 59)
History
Direct History
1District of Columbia v. De Hart, 73 App.D.C. 345, 119 F.2d 449 (App.D.C. Mar 24, 1941) (NO.
7779)
Certiorari Granted by
2District of Columbia v. Dehart, 313 U.S. 556, 61 S.Ct. 1104, 85 L.Ed. 1518 (U.S.Dist.Col. May 26,
1941) (NO. 992)
AND Judgment Reversed by
=> 3District of Columbia v. Murphy, 314 U.S. 441, 62 S.Ct. 303, 86 L.Ed. 329 (U.S.Dist.Col. Dec 15,
1941) (NO. 58, 59)
4District of Columbia v. Murphy, 73 App.D.C. 347, 119 F.2d 451 (App.D.C. Mar 24, 1941) (NO.
7780)
Certiorari Granted by
5District of Columbia v. Murphy, 313 U.S. 556, 61 S.Ct. 1103, 85 L.Ed. 1517 (U.S.Dist.Col. May 26,
1941) (NO. 991)
AND Judgment Reversed by
=> 6District of Columbia v. Murphy, 314 U.S. 441, 62 S.Ct. 303, 86 L.Ed. 329 (U.S.Dist.Col. Dec 15,
1941) (NO. 58, 59)
Court Documents
KEYCITE
District of Columbia v. Murphy, 314 U.S. 441, 62 S.Ct. 303, 86 L.Ed. 329 (U.S.Dist.Col., Dec 15, 1941) (NO.
58, 59)
KEYCITE
District of Columbia v. Murphy, 314 U.S. 441, 62 S.Ct. 303, 86 L.Ed. 329 (U.S.Dist.Col.
Dec 15, 1941) (NO. 58, 59)
Citing References
Examined
1Weitknecht v. District of Columbia, 195 F.2d 570, 571+, 90 U.S.App.D.C. 291, 292+ (D.C.Cir. Mar
20, 1952) (NO. 10906) " HN: 5,12,15 (S.Ct.)
2Pace v. District of Columbia, 135 F.2d 249, 250+, 77 U.S.App.D.C. 332, 333+ (App.D.C. Apr 12,
1943) (NO. 8274) HN: 10,11,16 (S.Ct.)
Discussed
3Commissioner of Internal Revenue v. Fiske's Estate, 128 F.2d 487, 490+, 42-2 USTC P 9485, 9485+,
29 A.F.T.R. 540, 540+ (C.C.A.7 May 23, 1942) (NO. 7846) " HN: 5,10,12 (S.Ct.)
4Arbaugh v. District of Columbia, 176 F.2d 28, 29+, 85 U.S.App.D.C. 97, 98+ (D.C.Cir. May 23,
1949) (NO. 9913) " HN: 3,5,12 (S.Ct.)
5Beckham v. District of Columbia, 163 F.2d 701, 701+, 82 U.S.App.D.C. 296, 296+ (App.D.C. Sep
15, 1947) (NO. 9470) " HN: 5,8,12 (S.Ct.)
6U.S. v. Scott, 472 F.Supp. 1073, 1076+, 79-2 USTC P 9439, 9439+ (N.D.Ill. Jun 18, 1979) (NO. 79
CR 236) HN: 15 (S.Ct.)
7In re Hodgson, 167 B.R. 945, 950+ (D.Kan. May 19, 1994) (NO. 89-42002-7, 90-7095, 92-4169-
RDR) " HN: 13 (S.Ct.)
8Medline Diamed, LLC v. Libassi, 2010 WL 5463831, *2+ (N.D.Ohio Dec 29, 2010) (NO. 5:10-CV-
02906) " HN: 13 (S.Ct.)
9Crawford v. U.S., 4 Cl.Ct. 699, 703+, 53 A.F.T.R.2d 84-1054, 84-1054+, 84-1 USTC P 9294, 9294+
(Cl.Ct. Mar 12, 1984) (NO. 156-80T) " HN: 3,16 (S.Ct.)
10Hall v. C.I.R., 1978 WL 3035, *1+, T.C. Memo. 1978-360, 1978-360+, 37 T.C.M. (CCH) 1500,
1500+, T.C.M. (P-H) P 78,360, 78360+ (U.S.Tax Ct. Sep 12, 1978) (NO. 6379-75) HN: 12 (S.Ct.)
11Taira v. Commissioner of Internal Revenue, 51 T.C. 662, 666+ (Tax Ct. Jan 29, 1969) (NO. 5240-64)
HN: 12,15 (S.Ct.)
12Bank-Fund Staff Federal Credit Union v. Cuellar, 639 A.2d 561, 573+ (D.C. Mar 15, 1994) (NO. 91-
CV-1325, 92-CV-282) " HN: 5,12 (S.Ct.)
13Andrews v. District of Columbia, 443 A.2d 566, 569+ (D.C. Apr 01, 1982) (NO. 81-78) " HN: 7,8,11
(S.Ct.)
14Alexander v. District of Columbia, 370 A.2d 1327, 1328+ (D.C. Feb 24, 1977) (NO. 8032) " HN:
5,8,12 (S.Ct.)
15Stephenson v. Stephenson, 134 A.2d 105, 106+ (D.C.Mun.App. Jul 01, 1957) (NO. 1979) " HN:
3,5,12 (S.Ct.)
Mentioned
157Martinez v. Bynum, 103 S.Ct. 1838, 1848, 461 U.S. 321, 340, 75 L.Ed.2d 879, 879, 10 Ed. Law Rep.
11, 11 (U.S.Tex. May 02, 1983) (NO. 81-857) (in dissent) HN: 16 (S.Ct.)
158Spiegel's Estate v. Commissioner of Internal Revenue., 69 S.Ct. 337, 356, 335 U.S. 632, 688, 93
L.Ed. 288, 288, 49 USTC P 10,702, 10702, 37 A.F.T.R. 495, 495 (U.S. Jan 17, 1949) (NO. 3, 5)
159Fisher v. U.S., 66 S.Ct. 1318, 1332, 328 U.S. 463, 491, 90 L.Ed. 1382, 1382, 166 A.L.R. 1176, 1176
(U.S.Dist.Col. Jun 10, 1946) (NO. 122) (in dissent) HN: 16 (S.Ct.)
160Northwest Airlines v. State of Minnesota, 64 S.Ct. 950, 953, 322 U.S. 292, 297, 88 L.Ed. 1283, 1283,
Court Documents
Trial Pleadings
332Shane WEYL, individually, and on behalf of other members of the general public similarly situated,
and as an aggrieved employee pursuant to the Private Attorneys General Act ("PAGA"), Plaintiffs, v.
DOLLAR TREE STORES, INC. and Does 1 through 10 , inclusive, Defendants., 2012 WL 4891035,
*1 (Trial Pleading) (C.D.Cal. Jul 26, 2012) Defendant's Notice of Removal (NO. CV12-6419-GW
(FFMX)) " HN: 8 (S.Ct.)
333Adina MEDEIROS, Plaintiff, v. ECOLAB INC., a Delaware corporation, and Does 1 through 100,
inclusive, Defendants., 2012 WL 4890812, *1 (Trial Pleading) (C.D.Cal. Jul 05, 2012) Notice to
Federal Court of Removal of Civil Action From State Court Pursuant to 28 U.S.C. Sections
1332(A)(1), 1441 and 1446 (NO. CV1205794JAKJCGX) " HN: 8 (S.Ct.)
334Doug LADORE, an Individual, for Himself and Those Similarly Situated; Moes 1 Through 3000 and
the Proposed Class, Plaintiffs, v. ECOLAB, INC., a Delaware Corporation; and Does 1 Through 100,
Inclusive, Defendants., 2011 WL 9349830, *1 (Trial Pleading) (C.D.Cal. Nov 10, 2011) Notice to
Federal Court of Removal of Civil Action from State Court Pursuant to 28 U.S.C. Sections
367Nariman ALI and Mohamed Ali, Plaintiff, v. HOME DEPOT U.S.A., INC., Defendant., 2003 WL
23639185, *23639185+ (Trial Pleading) (E.D.Pa. 2003) Home Depot's Memorandum of Law in
Opposition to Plaintiffs' Motion for Remand (NO. 03-2787) " HN: 8 (S.Ct.)
368Norma W. WILDE and Paul Wilde, her husband, Plaintiffs, v. MERCK AND CO, INC., Defendant.,
2012 WL 1689070, *1 (Trial Pleading) (W.D.Pa. May 04, 2012) Defendant Merck Sharp &
Dohme Corp.'s Notice of Removal (NO. 2:12CV00594) HN: 8 (S.Ct.)
369Anne M. HEALY-LIMING, Plaintiff, v. SPX FLOW TECHNOLOGY a/k/a Spx Process Equipment
a subsidiary of Spx Corporation, Defendant., 2011 WL 9191287, *1 (Trial Pleading) (S.D.Tex. Aug
26, 2011) Defendant's Notice of Removal (NO. 4:11-CV-03147) " HN: 8 (S.Ct.)
370Charles R. LAIN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent., 2010
WL 3317497, *3317497 (Trial Pleading) (U.S.Tax Ct. Aug 06, 2010) Petition (NO. 17840-10)
371Douglas R. CATON, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.,
2010 WL 806233, *806233 (Trial Pleading) (U.S.Tax Ct. 2010) Petition (NO. 5071-10)
398Thomas F. URBAN, II, Plaintiff, v. James F. HUMPHREYS; Cindy J. Kiblinger; and James F.
Humphreys & Associates, L.C., Defendants., 2007 WL 4460110, *4460110 (Trial Motion,
Memorandum and Affidavit) (D.D.C. Aug 27, 2007) Defendants' Response in Opposition to
Motion to Remand (NO. 107-CV-01367)
475In re, GATTA Robert A Jr., (Debtor)., 2007 WL 5322789, *5322789 (Trial Motion, Memorandum
and Affidavit) (Bankr.D.Mass. Feb 02, 2007) Memorandumof Law in Supporting of Debtors
Motion to Avoid Judical Lien on Residential Realestate (NO. 05-20524) HN: 15 (S.Ct.)
476In re Robert Louis MARRAMA, Debtor., 2004 WL 5621873, *5621873 (Trial Motion,
Memorandum and Affidavit) (Bankr.D.Mass. Jan 27, 2004) Memorandum of Law in Support of
Debtor's Reply to Objection of Citizens Bank to Certain Exemptions (NO. 103BK11987)
HN: 15 (S.Ct.)
477Ann Lee BUTLER, Debtor., 2004 WL 5620940, *5620940 (Trial Motion, Memorandum and
Affidavit) (Bankr.E.D.Tex. Feb 18, 2004) Debtor's Trial Brief (NO. 02-44217)
478Morris I. GLETZER a/k/a/ Morris I. Glecer, Plaintiff, v. Amos HARRIS, Defendant., 2005 WL
6460892, *6460892+ (Trial Motion, Memorandum and Affidavit) (N.Y.Sup. Feb 15, 2005)
Defendant's Reply Memorandum of Law in Further Support of his Motion to Reject the
Referee's Report and Recommendation and in Opposition to Plaintiff's Motion to Confirm the
Report (NO. 605036/01)
Trial Filings
479Jeremy CIOE, individually and on behalf of all others similarly situated, Plaintiff, v. PALM INC.,
Defendant., 2010 WL 4492549, *4492549 (Trial Filing) (N.D.Ill. Sep 24, 2010) Joint Jurisdictional
Status Report (NO. 10-CV-04994) HN: 9 (S.Ct.)