Legal Opinion
Commissioner v. Lundy
Supreme Court of the United States
Decided January 17, 1996No. 94-1785PublishedCited by 305 opinions
1Opinion of the CourtJustice O’Connor
In this case, we consider the “look-back” period for obtaining a refund of overpaid taxes in the United States Tax Court under 26 U. S. C. § 6512(b)(3)(B), and decide whether the Tax Court can award a refund of taxes paid more than two years prior to the date on which the Commissioner of Internal Revenue mailed the taxpayer a notice of deficiency, when, on the date the notice of deficiency was mailed, the taxpayer had not yet filed a return. We hold that in these circumstances the 2-year look-back period set forth in § 6512(b)(3)(B) applies, and the Tax Court lacks jurisdiction to award a…
2Cases cited17 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Sullivan v. StroopSupreme Court of the United States · 1990
- Sorenson v. Secretary of the TreasurySupreme Court of the United States · 1986
- United States v. KalesSupreme Court of the United States · 1941
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3Cited by305 opinions
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- Aziz v. Alcolac, Inc.Court of Appeals for the Fourth Circuit · 2011
- Minehan v. United StatesUnited States Court of Federal Claims · 2007
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