Howard Bank v. United States
District Court, D. Vermont
1Opinion of the Court
FINDINGS, CONCLUSIONS, OPINION AND ORDER
PARKER, District Judge.
Plaintiff The Howard Bank, as administrator of the Estate of Thomas C. Sawyer, filed suit seeking a refund of certain estate taxes paid to the United States. The United States Internal Revenue Service (IRS) concedes that it overassessed the value of the Sawyer Estate, but denied a refund on the sole ground that plaintiff failed to file suit within the statutory limitations period set forth in 26 U.S.C. § 6532(a). 1 The government’s motion to dismiss on the same ground, considered as a motion for summary judgment, was denied by the…
2Cases cited12 opinions
- Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
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- Juana Estela Corniel-Rodriguez v. Immigration and Naturalization ServiceCourt of Appeals for the Second Circuit · 1976
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