Legal Opinion
Hutchins v. Internal Revenue Service
Court of Appeals for the Third Circuit
Decided October 3, 1995No. 94-5509, 94-5510UnknownCited by 1 opinion
1Opinion of the Court
OPINION OF THE COURT
ROTH, Circuit Judge:
In this appeal, Charles T. Hutchins, appearing pro se, and the Internal Revenue Service each challenge aspects of the entry of summary judgment below. The district court granted summary judgment to the I.R.S. on its counterclaim to recoup an erroneous tax credit, but then, disturbed by this result, invoked equitable estoppel sua sponte to bar the I.R.S. from recovering all but a minor portion its claim. This holding necessarily denied Hutchins’ standing to sue for the original tax credit. We reverse. Hutch-ins had standing to pursue his original tax…
2Cases cited22 opinions
- Singleton v. WulffSupreme Court of the United States · 1976
- Hormel v. HelveringSupreme Court of the United States · 1941
- Goodman v. Mead Johnson & Co.Court of Appeals for the Third Circuit · 1976
- Newark Morning Ledger Company, a Corporation of the State of New Jersey v. The United States of AmericaCourt of Appeals for the Third Circuit · 1976
- Mervyn M. MERTZ, Appellee, v. JoAnn ROTT, Julie Rott Kessel, National Farmers Union Property and Casualty Company, AppellantsCourt of Appeals for the Eighth Circuit · 1992
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