Baral v. United States
Supreme Court of the United States
1Opinion of the CourtJustice Thomas
Internal Revenue Code § 6511(b)(2)(A) imposes a ceiling on the amount of credit or refund to which a taxpayer is entitled as compensation for an overpayment of tax: “[T]he amount of the credit or refund shall not exceed the portion of the tax paid within the period, immediately preceding the filing of the claim, equal to 3 years plus the period of any extension of time for filing the return.” 26 U. S. C. § 6511(b)(2)(A). We are called upon in this case to decide when two types of remittance are “paid” for purposes of this section: a remittance by a taxpayer of estimated income tax, and a…
2Cases cited7 opinions
- Commissioner v. LundySupreme Court of the United States · 1996
- Rosenman v. United StatesSupreme Court of the United States · 1945
- Tedroe J. Ford, Jr. And Margaret Ford v. United StatesCourt of Appeals for the Fifth Circuit · 1980
- David F. Ertman and Jane Ertman v. United StatesCourt of Appeals for the Second Circuit · 1999
- Owen A. Moran and Jean B. Moran v. United StatesCourt of Appeals for the Seventh Circuit · 1995
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3Cited by43 opinions
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- Danoff v. United StatesDistrict Court, C.D. California · 2004
- Dixon v. CommissionerUnited States Tax Court · 2013
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