Legal Opinion
O'Toole v. Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided December 11, 2002No. 02-55597; D.C. No. CV-01-00750-AHSPublishedCited by 2 opinions
1Opinion of the Court
MEMORANDUM **
Theodore O’Toole appeals pro se the district court’s judgment for the Internal Revenue Service (“IRS”) in his action seeking a tax refund. We have jurisdiction under 28 U.S.C. § 1291. We review de novo, Cement Masons Health & Welfare Trust Fund for No. Calif, v. Stone, 197 F.3d 1003, 1005 (9th Cir.1999), cert. denied, — U.S. -, 122 S.Ct. 902, 151 L.Ed.2d 871 (2002), and we affirm.
*962The district court properly concluded that because O’Toole did not file his administrative claim for a tax refund within two years of paying the tax, the administrative claim was untimely under 26 U.S.C.…
2Cases cited3 opinions
- United States v. BrockampSupreme Court of the United States · 1997
- Cement Masons Health And Welfare Trust Fund For Northern California v. Raymond StoneCourt of Appeals for the Ninth Circuit · 1999
- Imperial Plan, Inc., a Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1996
3Cited by2 opinions
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- Shaun Fleck v. National Credit Union AdministrationDistrict Court, D. Oregon · 2026