Legal Opinion
Allstate Insurance v. United States
United States Court of Claims
Decided February 23, 1977No. 380-73PublishedCited by 16 opinions
1Opinion of the CourtKunzig, Judge
The plaintiff, Allstate Insurance Company (Allstate), seeks to recover overpayments of Federal income taxes and interest for the taxable year ending December 31, 1969. The parties have stipulated that as a substantive matter, Allstate is entitled to all but $2,810.71 of the claimed refunds. However, defendant relies on Section 6511(b)(2) of the Internal Revenue Code of 1954 in contending that $127,907.18 of the refund is technically barred by the statute of limitations.1 For the reasons hereafter described, we hold the plaintiff not barred as to any part of the contested amount. Plaintiffs…
2Cases cited8 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- United States v. Memphis Cotton Oil Co.Supreme Court of the United States · 1933
- Rosenman v. United StatesSupreme Court of the United States · 1945
- Charlson Realty Company v. The United StatesUnited States Court of Claims · 1967
- A. H. Kelson and Nyla C. Kelson v. United StatesCourt of Appeals for the Tenth Circuit · 1974
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Computervision Corp. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Cencast Services, L.P. v. United StatesCourt of Appeals for the Federal Circuit · 2013
- Wertz v. United StatesUnited States Court of Federal Claims · 2002
- Trans-Lux Corporation v. The United StatesCourt of Appeals for the Federal Circuit · 1982
- Larson v. United StatesUnited States Court of Federal Claims · 2009
11 more not listed; retrieve them via the Exa API.