Legal Opinion
Electrolux Holdings, Inc. v. United States
Court of Appeals for the Federal Circuit
Decided June 20, 2007No. 2006-5106PublishedCited by 24 opinions
1Opinion of the Court
PLAGER, Senior Circuit Judge.
This is a taxing case. The general three-year statute of limitations for filing a federal tax refund claim is found in 26 U.S.C. § 6511(a). Subsection (d)(2)(A) of § 6511 establishes an exception to the general statute when the claim relates to an overpayment attributable to a capital loss carryback. This case involves the construction and application of this exception and presents an issue of first impression for this court.
The case arises out of a refund claim for the 1995 tax year submitted by White Consolidated Industries, Inc. (‘WCI”), the…
2Cases cited11 opinions
- Alexander v. SandovalSupreme Court of the United States · 2001
- Ve Holding Corporation v. Johnson Gas Appliance CompanyCourt of Appeals for the Federal Circuit · 1990
- Michael Strickland v. United StatesCourt of Appeals for the Federal Circuit · 2005
- Braunstein v. CommissionerSupreme Court of the United States · 1963
- Norfolk Dredging Company, Inc. v. United States, and Bean Stuyvesant, L.L.C.Court of Appeals for the Federal Circuit · 2004
6 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- MORI Associates, Inc. v. United StatesUnited States Court of Federal Claims · 2011
- Keener v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Candyce Martin 1999 Irrevocable Trust v. United StatesCourt of Appeals for the Ninth Circuit · 2014
- Prati v. United StatesUnited States Court of Federal Claims · 2008
- Georg Schaeffler v. United StatesCourt of Appeals for the Fifth Circuit · 2018
19 more not listed; retrieve them via the Exa API.