Legal Opinion
Cohen v. United States
United States Court of Claims
Decided August 6, 1991No. 90-187 TPublishedCited by 9 opinions
1Opinion of the Court
OPINION and ORDER
TURNER, Judge.
This tax refund action stands on plaintiffs’ motion for summary judgment and defendant’s cross-motion for partial summary judgment. Plaintiffs seek a refund of two amounts they sent to the IRS following their receipt of a notice of deficiency. The primary issues for decision are (i) whether plaintiffs’ first remittance to the IRS in partial satisfaction of the asserted deficiency, made prior to assessment and prior to the expiration of the statutory period for assessment, should be refunded on the sole ground that the subsequent deficiency assessment was…
2Cases cited20 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- John G. Rocovich, Jr. v. The United StatesCourt of Appeals for the Federal Circuit · 1991
- Rosenman v. United StatesSupreme Court of the United States · 1945
- Stange v. United StatesSupreme Court of the United States · 1931
- Charles Leich and Company v. The United StatesUnited States Court of Claims · 1964
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3Cited by9 opinions
- Sig and Barbara Shore v. United StatesCourt of Appeals for the Federal Circuit · 1993
- Thomas v. United StatesUnited States Court of Federal Claims · 2003
- James R. Cohen and Joanne D. Cohen v. The United StatesCourt of Appeals for the Federal Circuit · 1993
- Fisher v. United StatesUnited States Court of Federal Claims · 1993
- Principal Life Insurance v. United StatesUnited States Court of Federal Claims · 2010
4 more not listed; retrieve them via the Exa API.