Legal Opinion

Dickow v. United States

District Court, D. Massachusetts

Decided August 18, 2010No. Civil Action 09-10786-DPWPublishedCited by 5 opinions

1Opinion of the Court

MEMORANDUM AND ORDER

DOUGLAS P. WOODLOCK, District Judge.

Plaintiff D. Charles Dickow, as the Executor of the Estate of Margaret W. Dick-ow, seeks to recover federal estate tax he claims has been erroneously assessed and collected by the Internal Revenue Service (“IRS”) for the tax year ending on January 15, 2003. The IRS and the Executor have moved respectively for summary judgment and partial summary judgment over the issue of the timeliness of the Executor’s refund request. For the reasons stated below, I will grant the IRS summary judgment.

I. BACKGROUND

A. The Facts

Margaret W. Dickow died on…

2Cases cited25 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. United States v. TestanSupreme Court of the United States · 1976
  3. Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
  4. Office of Personnel Management v. RichmondSupreme Court of the United States · 1990
  5. United States v. BrockampSupreme Court of the United States · 1997

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3Cited by5 opinions

  1. Dickow v. United StatesCourt of Appeals for the First Circuit · 2011
  2. Abdallah v. Bain Capital LLCDistrict Court, D. Massachusetts · 2012
  3. V.R. Streeter v. United StatesDistrict Court, D. Massachusetts · 2015
  4. Axis Insurance Company v. Barracuda Networks, Inc.Court of Appeals for the First Circuit · 2025
  5. Merchia v. United States of AmericaDistrict Court, D. Massachusetts · 2019

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