Legal Opinion
First Security Bank of Idaho, N. A. v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided March 15, 1979No. 76-3641PublishedCited by 13 opinions
1Opinion of the Court
KILKENNY, Circuit Judge:
This is an appeal from the judgment of the tax court determining the amount of an overpayment of taxes by appellee for the year 1962 and ordering that the overpayment be used to offset the amounts of tax deficiencies determined for the years 1960 and 1961.
FACTS
On December 8, 1966, appellant issued a notice to appellee of tax deficiencies for the years 1960, 1961 and 1963. This notice also indicated an overassessment for the year 1962 and informed appellee that it would be applied in accordance with the provisions of Section 6402 of the Internal Revenue Code of 1954…
2Cases cited5 opinions
- United States v. KalesSupreme Court of the United States · 1941
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Helvering v. PfeifferSupreme Court of the United States · 1937
- Claire Morse v. United StatesCourt of Appeals for the Ninth Circuit · 1974
- Babetta Schmidt v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
3Cited by13 opinions
- Commissioner of Internal Revenue v. Gwendolyn A. Ewing, Gwendolyn A. Ewing v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Kelley v. CommissionerCourt of Appeals for the Ninth Circuit · 1995
- Fleetboston Financial Corp. v. United StatesUnited States Court of Federal Claims · 2005
- David M. Kelley David M. Kelley, Estate of Nancy I. Kelley, Deceased v. Commissioner Internal Revenue Service, David M. Kelley Mary L. Kelley v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Kazi v. CommissionerUnited States Tax Court · 1991
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