Legal Opinion
R.H. Donnelley Corp. v. United States
Court of Appeals for the Fourth Circuit
Decided March 31, 2011No. 10-1365PublishedCited by 7 opinions
1Opinion of the Court
Affirmed by published opinion. Judge WILKINSON wrote the opinion, in which Judge KEENAN and Judge BERGER joined.
OPINION
WILKINSON, Circuit Judge:
Just two days before the statute of limitations barred the Internal Revenue Service from assessing additional taxes for 1994, the R.H. Donnelley Corporation claimed refunds for 1991 and 1992 based on tax credits carried back from 1994. The statute of limitations then expired. After an investigation revealed that the taxpayer had so underreported its 1994 income that there was sufficient tax liability to use up all of the credits in that year, the IRS…
2Cases cited11 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Koons Buick Pontiac GMC, Inc. v. NighSupreme Court of the United States · 2004
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Philadelphia & Reading Corporation v. United StatesCourt of Appeals for the Third Circuit · 1991
- United States v. IdeCourt of Appeals for the Fourth Circuit · 2010
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3Cited by7 opinions
- United States v. Raymond Surratt, Jr.Court of Appeals for the Fourth Circuit · 2015
- Lockheed Martin Corp. v. United StatesDistrict Court, D. Maryland · 2013
- Delek US Holdings, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 2022
- Sanchez v. McLainDistrict Court, S.D. West Virginia · 2011
- Albemarle Corporation & Subsidiaries v. United StatesUnited States Court of Federal Claims · 2014
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