Legal Opinion
French v. Smyth
District Court, N.D. California
Decided October 14, 1952No. Nos. 6257, 6258PublishedCited by 9 opinions
1Opinion of the Court
LEMMON, District Judge.
Taxation, our Supreme Court has said, is “a subject that is highly specialized and so complex as to be the despair of judges”.1
The particular feature of tax law to be here considered is the effect of the taxpayers’ failure to assert, before the Collector of Internal Revenue, a ground for refund that they now seek to press before this Court. In their claims for refund, filed with the Collector, the taxpayers neglected to invoke the “forgiveness” feature of-the Current Tax Payment Act of 1943, 26 U.S.C.A. Int.Rev.Acts, p. 385 et seq.
To err is human, to forgive divine,…
2Cases cited21 opinions
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Taylor v. SecorSupreme Court of the United States · 1876
- United States v. Felt & Tarrant Manufacturing Co.Supreme Court of the United States · 1931
- Angelus Milling Co. v. CommissionerSupreme Court of the United States · 1945
- Tucker v. AlexanderSupreme Court of the United States · 1927
16 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Daley v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- Herbert P. Weinmann v. United StatesCourt of Appeals for the Second Circuit · 1960
- Richardson v. United StatesDistrict Court, S.D. Texas · 1971
- Daley v. United StatesCourt of Appeals for the Ninth Circuit · 1957
- French v. BerlinerCourt of Appeals for the Ninth Circuit · 1955
4 more not listed; retrieve them via the Exa API.