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Legal Opinion

Wrhel, Eric v. United States of America

District Court, W.D. Wisconsin

Decided September 18, 2023No. 3:21-cv-00424Unknown

1Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN ERIC T. WRHEL, Plaintiff, OPINION and ORDER v. 21-cv-424-jdp UNITED STATES OF AMERICA, Defendant. Eric T. Wrhel, appearing pro se, brings this lawsuit under

26 U.S.C. § 7422

to recover overpayments of income taxes for 2016 and 2018. Defendant United States has filed a motion for summary judgment, Dkt. 18, that I will grant because Wrhel’s claim about his 2016 overpayment is untimely and because the IRS properly offset his 2018 overpayment against a previous year’s unpaid tax debt. UNDISPUTED FACTS Wrhel has failed to…

2Cases cited12 opinions

  1. Hagner v. United StatesSupreme Court of the United States · 1932
  2. Estate of Leonard A. Wood, Deceased, J.M. Loonan, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
  3. Brian Miller v. United StatesCourt of Appeals for the Sixth Circuit · 1986
  4. David Deutsch v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
  5. Veronica Vincent v. City Colleges of Chicago, Ezekiel Morris, and Chicago Association of Realtors, Inc.Court of Appeals for the Seventh Circuit · 2007

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