Legal Opinion

Robin & Diane Miller, Husband and Wife v. United States

Court of Appeals for the Ninth Circuit

Decided October 20, 1994No. 93-35000PublishedCited by 27 opinions

1Opinion of the Court

WIGGINS, Circuit Judge:

Robin and Diane Miller (“Taxpayers”) seek a refund of federal income taxes withheld from their wages. They filed an action in district court pursuant to 28 U.S.C. § 1346(a)(1). The district court dismissed the action as untimely. We have jurisdiction over the final judgment pursuant to 28 U.S.C. § 1291 and affirm the district court.

FACTS

Taxpayers failed to prepare a timely income tax return for tax year 1986. In either June 1989 or February 1990, the Internal Revenue Service prepared a substitute return for that year pursuant to 26 U.S.C. (I.R.C.) § 6020(b). The IRS…

2Cases cited10 opinions

  1. William W. Boyd and Ruth G. Boyd v. United StatesCourt of Appeals for the Ninth Circuit · 1985
  2. Charles J. Oropallo v. United StatesCourt of Appeals for the First Circuit · 1993
  3. Dolores J. Russell v. United StatesCourt of Appeals for the Ninth Circuit · 1979
  4. United States v. Tami M. LecoeCourt of Appeals for the Ninth Circuit · 1991
  5. Allen v. CommissionerUnited States Tax Court · 1992

5 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. Commissioner v. LundySupreme Court of the United States · 1996
  2. Dunn & Black, P.S. v. United StatesCourt of Appeals for the Ninth Circuit · 2007
  3. Astrid E.A. Omohundro, Individually and as the Beneficiary of the Estate of Stuart W. Omohundro v. United StatesCourt of Appeals for the Ninth Circuit · 2002
  4. Marsha Hatch Ingham v. United StatesCourt of Appeals for the Ninth Circuit · 1999
  5. Imperial Plan, Inc., a Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1996

22 more not listed; retrieve them via the Exa API.

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