Legal Opinion
Grapevine Imports, Ltd. v. United States
Court of Appeals for the Federal Circuit
Decided March 11, 2011No. 2008-5090PublishedCited by 26 opinions
1Opinion of the Court
PROST, Circuit Judge.
The government appeals the U.S. Court of Federal Claims’ judgment that the Internal Revenue Service’s (“IRS’s”) 2004 administrative adjustment of Plaintiffs’ 1999 partnership return was time-barred. Grapevine Imports, Ltd. v. United States, 77 Fed.Cl. 505 (2007). The question is whether administrative adjustments in these circumstances are governed by the normal three-year statute of limitations, or whether they are controlled by a special six-year limitations period.
The Tax Code gives the IRS six years instead of three to adjust a return when the return “omits” some item…
2Cases cited29 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Bowen v. Georgetown University HospitalSupreme Court of the United States · 1988
- National Cable & Telecommunications Assn. v. Brand X Internet ServicesSupreme Court of the United States · 2005
24 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Salman Ranch, Ltd. v. CommissionerCourt of Appeals for the Tenth Circuit · 2011
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- David King v. Sylvia BurwellCourt of Appeals for the Fourth Circuit · 2014
- Intermountain Insurance Service of Vail v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2011
- John Thorpe v. Borough of Jim ThorpeCourt of Appeals for the Third Circuit · 2014
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