Legal Opinion
Samuel v. Sotir and Norman P. Johnson v. United States
Court of Appeals for the First Circuit
Decided October 30, 1992No. 92-1061PublishedCited by 8 opinions
1Opinion of the Court
BOUDIN, Circuit Judge.
The sole question presented on this appeal is whether, when a taxpayer with several tax liabilities sends a payment to the Internal Revenue Service but fails to specify the liability to which the payment applies, the IRS may apply the payment to the liability it chooses. In agreement with the district court in this case and in accord with other circuits, we hold that the IRS may make this choice.
Samuel V. Sotir and Norman P. Johnson were officers, directors and shareholders of R & M Industries, Inc. (“R & M”), a Massachusetts corporation. The corporation incurred two…
2Cases cited7 opinions
- Begier v. Internal Revenue ServiceSupreme Court of the United States · 1990
- United States v. Energy Resources Co.Supreme Court of the United States · 1990
- National Bank of the Commonwealth v. Mechanics' National BankSupreme Court of the United States · 1877
- Fredric C. Muntwyler v. United StatesCourt of Appeals for the Seventh Circuit · 1983
- Dan O. Davis, Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-AppelleeCourt of Appeals for the Ninth Circuit · 1992
2 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Larson v. United StatesUnited States Court of Federal Claims · 2009
- Teets v. United StatesUnited States Court of Federal Claims · 1993
- Pullman Construction Industries, Inc. v. United States (In Re Pullman Construction Industries, Inc.)United States Bankruptcy Court, N.D. Illinois · 1995
- Kitaeff v. Massachusetts Bay Transportation Authority (In re Bay State York Co.)United States Bankruptcy Court, D. Massachusetts · 1996
- Looney v. United StatesDistrict Court, S.D. Texas · 2008
3 more not listed; retrieve them via the Exa API.