Legal Opinion
Davis v. United States
United States Court of Claims
Decided July 26, 1990No. 451-89TPublishedCited by 8 opinions
1Opinion of the Court
OPINION
RADER, Judge:
In this tax refund suit, plaintiffs seek repayment of a disallowed deduction for rent on business property. Defendant moved to dismiss in part under the doctrine of variance. Defendant contends that plaintiffs did not give the Internal Revenue Service (IRS) adequate notice of their grounds for refund as required by 26 U.S.C. § 7422(a) (1988). Plaintiffs claim to have alerted the IRS of the grounds for the refund. In light of the adequate definition of law and facts in this case, oral argument is not necessary. This court denies defendant’s motion.
Facts
On December 17, 1983,…
2Cases cited11 opinions
- Tucker v. AlexanderSupreme Court of the United States · 1927
- James P. Thomas and Mary Lou Thomas v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1986
- Thomas v. CommissionerUnited States Tax Court · 1985
- Union Pacific Railroad Company v. The United StatesUnited States Court of Claims · 1968
- Hunter Faulconer, Sr. And Mary T. Faulconer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1984
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Cencast Services, L.P. v. United StatesUnited States Court of Federal Claims · 2010
- Heger v. United StatesUnited States Court of Federal Claims · 2012
- Levitsky v. United StatesUnited States Court of Federal Claims · 1992
- Boddie-Noell Enterprises, Inc. v. United StatesUnited States Court of Federal Claims · 1996
- Estate of Liftin v. United StatesUnited States Court of Federal Claims · 2013
3 more not listed; retrieve them via the Exa API.