Legal Opinion
Pacific Gas & Electric Co. v. United States
Court of Appeals for the Federal Circuit
Decided August 10, 2005No. 2003-5173PublishedCited by 13 opinions
1Opinion of the Court
ARCHER, Senior Circuit Judge.
Pacific Gas and Electric Company and PG & E Corporation (collectively “PGÉ”) appeal the United States Court of Federal Claims’ judgment that the Internal Revenue Service (“IRS” or “Service”) properly offset statutory interest that was erroneously paid to PGE (“erroneous interest”) with respect to the tax year 1982, against a later refund of tax and interest determined to be due PGE for the same tax year. Pac. Gas & Elec. Co. v. United States, 55 Fed.Cl. 271 (2003) (“PGE I”). Because the IRS made this offset after the statute of limitations under 26 U.S.C. §…
2Cases cited10 opinions
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Samuel C. Dysart and Alma R. Dysart v. The United StatesUnited States Court of Claims · 1965
- Raymond E. And Dorothy J. O'Bryant v. United StatesCourt of Appeals for the Seventh Circuit · 1995
- Alexander Proudfoot Co. v. United StatesUnited States Court of Claims · 1972
5 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- American Airlines, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2008
- Willson v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2015
- Sunoco Inc. v. CommissionerCourt of Appeals for the Third Circuit · 2011
- Brittani Nicole Williams v. United StatesUnited States Court of Federal Claims · 2013
- Pennoni v. United StatesUnited States Court of Federal Claims · 2007
8 more not listed; retrieve them via the Exa API.