Legal Opinion

Liu v. United States

United States Court of Federal Claims

Decided June 11, 2010No. 09-693TPublishedCited by 2 opinions

1Opinion of the Court

OPINION AND ORDER

DAMICH, Judge.

Plaintiff Sean M. Liu has filed suit against the United States for the return of income tax under 26 U.S.C. § 6511(a), (d)(3). Defendant United States (“the Government”) now moves the Court, pursuant to Rule 12(b)(1) of the Rules of the Court of Federal Claims (“RCFC”), to dismiss this action for lack of subject matter jurisdiction because the complaint was not timely filed. Plaintiff cross-moves the Court to correct the filing date of his complaint.

For the reasons set forth below, the Court DENIES the Government’s motion to dismiss and GRANTS Plaintiffs motion…

2Cases cited26 opinions

  1. Haines v. KernerSupreme Court of the United States · 1972
  2. Harlow v. FitzgeraldSupreme Court of the United States · 1982
  3. Scheuer v. RhodesSupreme Court of the United States · 1974
  4. Steel Co. v. Citizens for a Better EnvironmentSupreme Court of the United States · 1998
  5. Arbaugh v. Y & H Corp.Supreme Court of the United States · 2006

21 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. James M. Langan, Jr., as the of the Estate of Eleanor F. Langan v. United StatesUnited States Court of Federal Claims · 2013
  2. Minburn Technology Group, LLC v. United StatesUnited States Court of Federal Claims · 2026

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