Legal Opinion
First National Bank v. United States
United States Court of Claims
Decided February 22, 1978No. 135-77PublishedCited by 17 opinions
1Opinion of the CourtCowen, Senior Judge
This case raises the issue whether the last sentence of 26 U.S.C. § 2055 (e)(3) (Supp. V. 1975) violates the equal protection clause of the 14th Amendment as included in the Fifth Amendment’s due process clause.1 The sentence in question will not permit interest to be paid to a taxpayer until 180 days after he has filed a claim for refund, if the refund is made possible by the reformation of a trust pursuant to section 2055(e)(3) for the purpose of permitting *611a charitable deduction in accordance with section 2055(e)(2)(A). We hold that the provision in issue withstands plaintiffs…
2Cases cited16 opinions
- Dandridge v. WilliamsSupreme Court of the United States · 1970
- McGowan v. MarylandSupreme Court of the United States · 1961
- Bolling v. SharpeSupreme Court of the United States · 1954
- City of New Orleans v. DukesSupreme Court of the United States · 1976
- F. S. Royster Guano Co. v. VirginiaSupreme Court of the United States · 1920
11 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Mapes v. United StatesUnited States Court of Claims · 1978
- Black v. Secretary of the Department of Health & Human ServicesUnited States Court of Federal Claims · 1995
- Warren G. Wheeler, Jr., Jean M. Wheeler, James J. McLaughlin Jr., and Mary K. McLaughlin v. The United StatesCourt of Appeals for the Federal Circuit · 1985
- Burke Mountain Academy, Inc., Appellant-Plaintiff v. United States of America, Appellee-DefendantCourt of Appeals for the Second Circuit · 1983
- Di Portanova v. United StatesUnited States Court of Claims · 1982
12 more not listed; retrieve them via the Exa API.