Legal Opinion

Kellogg-Citizens National Bank of Green Bay, Wisconsin, of the Estate of Joseph B. Holzer, Deceased v. The United States

United States Court of Claims

Decided April 17, 1964No. 108-62PublishedCited by 24 opinions

1Opinion of the Court

DAVIS, Judge.

In this estate tax refund suit, the first question to be decided is whether the taxpayer filed a timely claim with the Internal Revenue Service asking for the refund now sought. On that threshold issue the facts are undisputed. Plaintiff, as the executor of the estate of Joseph B. Holzer who died on April 21, 1954, filed an estate tax return on April 26 or 27, 1955, and immediately paid an estate tax of $26,275.37. About two years later, on June 25, 1957, the Internal Revenue Service issued deficiency notices claiming additional income tax and penalties (aggregating $111,581.45)…

2Cases cited12 opinions

  1. American Radiator & Standard Sanitary Corp. v. United StatesUnited States Court of Claims · 1963
  2. United States v. ZacksSupreme Court of the United States · 1963
  3. National Forge & Ordnance Company v. United StatesUnited States Court of Claims · 1957
  4. Sherman B. Harlan, Receiver for General Credit Corporation v. The United StatesUnited States Court of Claims · 1963
  5. Aaron Zacks and Florence Zacks v. United StatesUnited States Court of Claims · 1960

7 more not listed; retrieve them via the Exa API.

3Cited by24 opinions

  1. Nager Electric Company, Inc. And Keystone Engineering Corporation v. The United StatesUnited States Court of Claims · 1966
  2. Neer v. State Ex Rel. Oklahoma Tax CommissionSupreme Court of Oklahoma · 1999
  3. National Labor Relations Board v. Northern Metal CompanyCourt of Appeals for the Third Circuit · 1971
  4. Sun Chemical Corp., a Delaware Corporation v. The United StatesCourt of Appeals for the Federal Circuit · 1983
  5. Ray v. United StatesUnited States Court of Claims · 1972

19 more not listed; retrieve them via the Exa API.

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