Legal Opinion

Keener v. United States

United States Court of Federal Claims

Decided April 18, 2007No. Nos. 03-2028T, 04-907TPublishedCited by 33 opinions

1Opinion of the Court

OPINION

ALLEGRA, Judge.

In this tax suit, Kenneth C. Keener, William P. Smith and Anne D. Smith (collectively plaintiffs) seek refunds of federal income taxes and interest paid in connection with their investments in various partnerships. At issue on defendant’s motion for partial dismissal of plaintiffs’ complaints is whether this court has jurisdiction, notwithstanding 26 U.S.C. § 7422(h), to entertain plaintiffs’ claims that: (i) Notices of Final Partnership Administrative Adjustments (FPAAs) were untimely filed by the Internal Revenue Service (IRS) and cannot support the tax assessments…

2Cases cited66 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  3. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  4. United States v. BasyeSupreme Court of the United States · 1973
  5. Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985

61 more not listed; retrieve them via the Exa API.

3Cited by33 opinions

  1. Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
  2. Keener v. United StatesCourt of Appeals for the Federal Circuit · 2009
  3. Prati v. United StatesCourt of Appeals for the Federal Circuit · 2010
  4. Prati v. United StatesUnited States Court of Federal Claims · 2008
  5. Prati v. United StatesUnited States Court of Federal Claims · 2008

28 more not listed; retrieve them via the Exa API.

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