Legal Opinion
Wm. J. Friday & Co. v. United States
Court of Appeals for the Third Circuit
Decided September 19, 1932No. 4618PublishedCited by 5 opinions
1Opinion of the Court
WOOLLEY, Circuit Judge.
The appellant taxpayer had overpaid its income and profits taxes for the year 1919. Having failed to avail itself, within the statutory period, of the remedy by which it could recover the overpayment in proceedings for a refund of a tax illegally assessed or collected (section 3226, R. S. [26 USCA § 156]), it brought this suit on a certificate of overpayment by the Commissioner of Internal Revenue on the theory that it could recover on the government’s implied promise to pay what the Commissioner had certified was due it. The main question in the ease is not whether…
2Cases cited9 opinions
- Slocum v. New York Life InsuranceSupreme Court of the United States · 1913
- Robertson v. CeaseSupreme Court of the United States · 1878
- Bonwit Teller & Co. v. United StatesSupreme Court of the United States · 1931
- Girard Trust Co. v. United StatesSupreme Court of the United States · 1926
- United States Ex Rel. Cateches v. DaySupreme Court of the United States · 1931
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Dorrance v. PhillipsCourt of Appeals for the Third Circuit · 1936
- Gans S. S. Line v. BowersCourt of Appeals for the Second Circuit · 1936
- Atkinson v. United StatesDistrict Court, D. Minnesota · 1933
- Hart Glass Mfg. Co. v. United StatesCourt of Appeals for the Seventh Circuit · 1941
- Leisenring v. United StatesUnited States Court of Claims · 1933