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Legal Opinion

First National Bank of Chicago v. United States

Court of Appeals for the First Circuit

Decided June 24, 1986No. 84-6496PublishedCited by 16 opinions

1Opinion of the Court

HUG, Circuit Judge:

This appeal principally concerns an interpretation of section 6512(a) of the Internal Revenue Code, 26 U.S.C. § 6512(a) (1982). The Government contends that section 6512(a) deprives the district court of jurisdiction to hear the estate’s claim for refund because the estate had previously filed a petition with the Tax Court contesting a deficiency assessed by the Internal Revenue Service (“IRS”). We agree with the Government’s contention and reverse the district court’s award of a refund.

First National Bank of Chicago was trustee of six irrevocable inter vivos trusts…

2Cases cited7 opinions

  1. California v. LaRueSupreme Court of the United States · 1973
  2. Elbert v. JohnsonCourt of Appeals for the Second Circuit · 1947
  3. Estate of Bailly v. CommissionerUnited States Tax Court · 1983
  4. Moir v. United StatesCourt of Appeals for the First Circuit · 1945
  5. United States v. WolfCourt of Appeals for the Ninth Circuit · 1956

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3Cited by16 opinions

  1. Richard D. Bokum, Ii, Margaret B. Bokum v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
  2. Building Material & Dump Truck Drivers, Local 420 v. TraweekCourt of Appeals for the Ninth Circuit · 1989
  3. David A. Koss Freya B. Koss v. United StatesCourt of Appeals for the Third Circuit · 1995
  4. Solitron Devices, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1989
  5. Building Material and Dump Truck Drivers, Local 420 and International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America, Plaintiffs v. Oliver Traweek and Gene McFadden v. Gene True Edgar Smith Richard Martino Pete Gallegos Leo Pittman Arthur Webb and Clyde Craig, Third-Party-Defendants-Appellants. Building Material and Dump Truck Drivers, Local 420, and International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America v. Richard Martino Edgar Smith and Gene True, and Oliver Traweek and Gene McFadden Defendants-Counterclaim-Third-PartyCourt of Appeals for the Third Circuit · 1989

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