Legal Opinion
Rye v. United States
United States Court of Claims
Decided March 30, 1992No. 151-89TPublishedCited by 2 opinions
1Opinion of the Court
OPINION
ROBINSON, Judge.
Plaintiffs, Jonathan P. and Lisa A. Rye,1 have brought suit under the Tucker Act, 28 U.S.C. § 1491 (1988), seeking a refund of $487,490.77 in taxes and interest paid for the 1981 tax year. Defendant, the United States of America, opposes plaintiffs’ re*593covery, and both parties have moved for summary judgment. At issue in this proceeding is whether the amendments to § 453 of the Internal Revenue Code of 19542 contained in the Installment Sales Revision Act of 1980 (1980 Revision Act) alter the rule, as established by case law, that no portion of a private annuity payment…
2Cases cited15 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Morton v. MancariSupreme Court of the United States · 1974
- Mingus Constructors, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1987
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3Cited by2 opinions
- Wittman v. KoenigCourt of Appeals for the Seventh Circuit · 2016
- Mark J. Wittman v. Timothy A. KoenigCourt of Appeals for the Seventh Circuit · 2016