Legal Opinion
Richard T. Gallion and Audrey R. Gallion v. United States
Court of Appeals for the Fifth Circuit
Decided February 13, 1968No. 24352_1PublishedCited by 13 opinions
1Opinion of the Court
COLEMAN, Circuit Judge:
Section 6532 of the Internal Revenue Code of 1954 [as amended by Sec. 89(b), Technical Amendments Act of 1958, P. L. 85 — 866, 72 Stat. 1606] provides as follows:
“(a) Suits by Taxpayers for Refund.—(1) General rule. — No suit or proceeding under section 7422(a) for the recovery of any internal revenue tax, penalty, or other sum, shall be begun before the expiration of 6 months from the date of filing the claim required under such section unless the Secretary or his delegate renders a decision thereon within that time, nor after the expiration of 2 years from the date of…
2Cases cited12 opinions
- Finn v. United StatesSupreme Court of the United States · 1887
- United States v. MichelSupreme Court of the United States · 1931
- United States v. Garbutt Oil Co.Supreme Court of the United States · 1938
- Joseph Delman and Jeanette Delman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
- Ritter v. United StatesCourt of Appeals for the Third Circuit · 1928
7 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Emma Reynolds v. United StatesCourt of Appeals for the Fifth Circuit · 1984
- Ned Miller and Frances Miller v. The United States of AmericaCourt of Appeals for the Second Circuit · 1974
- Bobby Wayne Goff v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Dr. Clayton H. Smith and Doris Jean Smith v. United StatesCourt of Appeals for the Fifth Circuit · 1973
- Stuyvesant Insurance Co. v. Department of TreasuryDistrict Court, S.D. New York · 1974
8 more not listed; retrieve them via the Exa API.