Legal Opinion
Sebough S. Shields v. United States
Court of Appeals for the Sixth Circuit
Decided March 23, 1967No. 16653PublishedCited by 8 opinions
1Opinion of the Court
O’SULLIVAN, Circuit Judge.
The District Court for the Northern District of Ohio, Eastern Division, dismissed the suit of appellant-taxpayer, Sebough S. Shields, who sought a refund of $59,529.31 of income taxes and interest thereon, paid by appellant to defendant-appellee, United States. The tax year involved was 1951 and the assessment was made by the Commissioner on June 29,1962. Such assessment was barred by the statute of limitations, Int. Rev.Code of 1939, § 275(a), (c) unless the Commissioner was correct and timely in applying the “mitigation provisions” of Sections 1311-1315 of the…
2Cases cited8 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Gallagher v. SmithCourt of Appeals for the Third Circuit · 1955
- Will Flitcroft and Agnes D. Flitcroft v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Estate of Isaac G. Darlington, Provident Tradements Bank and Trust Company and Claude C. Smith, Executors v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Old Kent Bank & Trust Co. v. United StatesCourt of Appeals for the Sixth Circuit · 1966
3 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Davis v. CommissionerUnited States Tax Court · 1970
- Hartzog v. United StatesUnited States Court of Claims · 1984
- Fruit of the Loom v. CommissionerUnited States Tax Court · 1994
- Brummett v. United StatesDistrict Court, D. Oregon · 2002
- Davis v. CommissionerUnited States Tax Court · 1970
3 more not listed; retrieve them via the Exa API.