Legal Opinion

Montana Rail Link, Inc. v. United States

Court of Appeals for the Ninth Circuit

Decided February 12, 1996No. 94-36202PublishedCited by 17 opinions

1Opinion of the Court

D.W. NELSON, Circuit Judge:

Montana Rail Link (“MRL”) appeals the district court’s dismissal of its action to obtain a refund of taxes paid in 1987 and 1988. MRL asserts that § 10206(c) (2) (A)(ii) of the Omnibus Budget Reconciliation Act of 1989 (“OBRA”) violates due process by retroactively barring refund claims by employers who believed that their 401(k) plan contributions were subject to tax under the Railroad Retirement Tax Act (“RRTA”). 1 We affirm the court’s judgment, on the grounds that § 10206(c)(2)(A)(ii) is supported by a legitimate legislative purpose furthered by rational means.…

2Cases cited4 opinions

  1. United States v. CarltonSupreme Court of the United States · 1994
  2. Reich v. CollinsSupreme Court of the United States · 1994
  3. Anthony C. And Mildred M. Licari v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1991
  4. Montana Rail Link, Inc. v. United StatesDistrict Court, D. Montana · 1994

3Cited by17 opinions

  1. General Motors Corp. v. Department of TreasuryMichigan Court of Appeals · 2010
  2. Hambleton v. Department of RevenueWashington Supreme Court · 2014
  3. J. Thomas Zaber, On Behalf Of Himself And All Others Similarly Situated Vs. City Of Dubuque, IowaSupreme Court of Iowa · 2010
  4. BNSF Railway Company v. United StatesCourt of Appeals for the Fifth Circuit · 2015
  5. River Garden Retirement Home v. Franchise Tax BoardCalifornia Court of Appeal · 2010

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