Legal Opinion
Fortugno v. Commissioner
Court of Appeals for the Third Circuit
Decided November 19, 1965No. Nos. 15210-15217PublishedCited by 16 opinions
1Opinion of the Court
BIGGS, Chief Judge.
The taxpayer-petitioners1 seek review of decisions of the Tax Court of the United States which held that certain portions of monies remitted by them to the United States were not “overpayments” within the meaning of Section 3771(a) of the Internal Revenue Code of 1939, 26 U.S.C.A., and that therefore the petitioners were not entitled to interest on the portions of the sums remitted, as hereinafter indicated.2
In 1950 the United States Internal Revenue Service commenced an investigation of the income tax liability of the taxpayers and of the ownership of a fertilizer…
2Cases cited17 opinions
- Rosenman v. United StatesSupreme Court of the United States · 1945
- United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961
- Lewyt Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- United States v. Dubuque Packing Company, a Corporation, Dubuque Packing Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1956
- Thomas v. Mercantile Nat. Bank at DallasCourt of Appeals for the Fifth Circuit · 1953
12 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Arthur C. Ewing A/K/A A. Clifford Ewing Maxine H. Ewing v. United StatesCourt of Appeals for the Fourth Circuit · 1990
- 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
- Risman v. CommissionerUnited States Tax Court · 1993
- Blatt v. United StatesDistrict Court, W.D. North Carolina · 1993
11 more not listed; retrieve them via the Exa API.