Legal Opinion

Northern Natural Gas Co. v. O'Malley

Court of Appeals for the Eighth Circuit

Decided April 13, 1960No. Nos. 16238, 16239PublishedCited by 1 opinion

1Opinion of the Court

VAN OOSTERHOUT, Circuit Judge.

These actions, consolidated for trial and upon appeal, are for the recovery of federal income taxes alleged to have been *130illegally assessed and collected for the years 1946 through 1951. Timely refund claims were filed and disallowed. These suits were commenced within the time permitted by law. The defendant in each action is the collector of internal revenue in office at the time the tax was paid. The collectors represented the Commissioner and acted under his direction. For convenience and simplicity, we will hereafter refer to the Commissioner as the defendant.

2Cases cited29 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  4. Dobson v. CommissionerSupreme Court of the United States · 1944
  5. Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936

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3Cited by1 opinion

  1. Northern Natural Gas Company v. John A. O'malley, Administrator of the Estate of George W. O'malley, Deceased, Northern Natural Gas Company v. James L. McCroryCourt of Appeals for the Eighth Circuit · 1960

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