Legal Opinion
Starkey v. United States
District Court, W.D. Arkansas
Decided February 25, 1986No. Civ. 85-3032PublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OPINION
H. FRANKLIN WATERS, Chief Judge.
Before the court is the motion of the United States to dismiss plaintiffs’ cause of action on grounds that the suit was not filed within the two-year period prescribed by the statute of limitations. 26 U.S.C. § 6532. In reply, plaintiffs argue that the United States should be equitably estopped from pleading the statute by virtue of the following facts: (1) That in January, 1983, the Starkeys filed a claim for refund with the IRS and asked that it be given an expedited denial so that the Director’s interpretation of their business transaction…
2Cases cited4 opinions
- United States v. SherwoodSupreme Court of the United States · 1941
- The HarrisburgSupreme Court of the United States · 1886
- Soriano v. United StatesSupreme Court of the United States · 1957
- Robert J. And Nancy J. Huettl v. United StatesCourt of Appeals for the Ninth Circuit · 1982
3Cited by3 opinions
- In Re Long-Distance Telephone Service Federal Excise Tax Refund LitigationDistrict Court, District of Columbia · 2007
- Getter v. BeckmanMontana Supreme Court · 1989
- Vintilla v. United StatesDistrict Court, M.D. Florida · 1990