Legal Opinion

Robert Stocker, II v. United States

Court of Appeals for the Sixth Circuit

Decided January 17, 2013No. 11-1890PublishedCited by 18 opinions

1Opinion of the Court

OPINION

ROSEN, Chief District Judge.

I. INTRODUCTION

This ease truly presents a “$64,000 Question” 1 —namely, what sort of proof the PlaintiffAppellant taxpayers, Robert W. Stocker, II and Laurel A. Stocker (the Stockers), may introduce in order to demonstrate the timely filing of a tax return in which they sought a federal tax refund of just over $64,000. The Internal Revenue Service (IRS) denied this claim for a refund on the ground that the Stockers failed to file their amended 2003 federal tax return within the statutory three-year period for amending a return. The Stock-ers then brought…

2Cases cited13 opinions

  1. United States v. TestanSupreme Court of the United States · 1976
  2. United States v. DalmSupreme Court of the United States · 1990
  3. Beaven v. United States Department of JusticeCourt of Appeals for the Sixth Circuit · 2010
  4. Lois Anderson v. United StatesCourt of Appeals for the Ninth Circuit · 1992
  5. Estate of Leonard A. Wood, Deceased, J.M. Loonan, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990

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3Cited by18 opinions

  1. Mark Zanecki v. Health Alliance Plan of DetroitCourt of Appeals for the Sixth Circuit · 2014
  2. United States v. Harold (In re Harold)United States Bankruptcy Court, E.D. Michigan · 2018
  3. Basey v. United StatesDistrict Court, E.D. Kentucky · 2023
  4. Crossley v. Kettering Adventist HealthcareDistrict Court, S.D. Ohio · 2023
  5. Debbie L. Dowell v. Department of the Interior, Doug Burgum, Secretary of the Interior, et al.District Court, M.D. Tennessee · 2026

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