Legal Opinion
Samuel M. Longiotti Betty C. Longiotti v. United States
Court of Appeals for the Fourth Circuit
Decided June 15, 1987No. 86-2579PublishedCited by 21 opinions
1Opinion of the Court
WILKINSON, Circuit Judge:
Appellants Samuel M. and Betty C. Lon-giotti claim a refund of federal income taxes based on certain net operating loss carrybacks. The district court granted the government’s motion for summary judgment on the ground that the claim was barred by the thirty-nine and a half month statute of limitations set out in section 6511(d)(2)(A) of the Internal Revenue Code. We affirm.
I
Taxpayers suffered net operating losses (NOLs) in 1973 and 1974. They deducted these losses as carryovers in 1976, 1978 and 1979. In 1975, the IRS issued a notice of deficiency for $324,423.57 on…
2Cases cited8 opinions
- Kavanagh v. NobleSupreme Court of the United States · 1948
- Commissioner v. KorellSupreme Court of the United States · 1950
- Olin Mathieson Chemical Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1959
- Jack O. Chertkof and Sophie Chertkof v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1981
- Mar Monte Corporation v. United StatesCourt of Appeals for the Ninth Circuit · 1974
3 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Marshall M. Chernin Ida Raye Chernin, Cross-Appellants/appellees v. United States of America, Appellant/cross-AppelleeCourt of Appeals for the Eighth Circuit · 1998
- Joseph D. Griggs v. E.I. Dupont De Nemours & CompanyCourt of Appeals for the Fourth Circuit · 2004
- Stephens v. United StatesCourt of Appeals for the Federal Circuit · 2018
- TLI, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1996
- Milton I. Schwartz Nina Schwartz v. United StatesCourt of Appeals for the Ninth Circuit · 1995
16 more not listed; retrieve them via the Exa API.