Legal Opinion
Hartzog v. United States
United States Court of Claims
Decided December 13, 1984No. 169-82TPublishedCited by 6 opinions
1Opinion of the Court
OPINION
YOCK, Judge:
This case comes before the Court on the defendant’s motion to dismiss filed on the grounds that the Court lacks subject matter jurisdiction over the plaintiffs’ claim, since the claim was not timely filed and the mitigation provisions of 26 U.S.C. § 1311 are inapplicable by their terms to relieve the plaintiffs from the jurisdictional defect. The plaintiffs have filed a response and the defendant a reply. For the reasons stated below, the defendant’s motion to dismiss is granted.
Facts
The plaintiffs, Thomas S. and Joye B. Hartzog (“plaintiffs”), on September 15, 1973, timely…
2Cases cited10 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Frank Erickson and Amelia Erickson v. The United StatesUnited States Court of Claims · 1962
- Hord v. United StatesUnited States Court of Claims · 1932
- Morgan v. United StatesUnited States Court of Claims · 1934
- Sebough S. Shields v. United StatesCourt of Appeals for the Sixth Circuit · 1967
5 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Money v. CommissionerUnited States Tax Court · 1987
- Weiner v. United StatesUnited States Court of Claims · 1988
- Thomas E. Johnston, and Thomas E. Johnston, Successor in Interest to Shirley L. Johnston, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- 1900 M Restaurant Associates, Inc. v. United States (In Re 1900 M Restaurant Associates, Inc.)District Court, District of Columbia · 2005
- Johnston v. CirCourt of Appeals for the Ninth Circuit · 2006
1 more not listed; retrieve them via the Exa API.