Legal Opinion
Radin v. United States
District Court, D. Connecticut
Decided December 19, 1988No. Civ. N-88-130 (PCD)PublishedCited by 3 opinions
1Opinion of the Court
RULING ON MOTION TO DISMISS
DORSEY, District Judge.
I. Background
Plaintiff claims a credit of $17,361.01 on his 1981 tax return, which he requested be applied to his 1982 estimated tax. This credit was denied by the Internal Revenue Service (“IRS”) on the ground that the credit claim (in the form of his 1981 tax return) was filed more than three years after the tax was paid and thus after the time allowed by statute for claiming a credit or refund.
Plaintiff’s 1980 tax return contained a net overpayment of $16,249.43, which plaintiff elected to have applied to his 1981 estimated tax. However,…
2Cases cited14 opinions
- Conley v. GibsonSupreme Court of the United States · 1957
- Scheuer v. RhodesSupreme Court of the United States · 1974
- United States v. Memphis Cotton Oil Co.Supreme Court of the United States · 1933
- George Moore Ice Cream Co. v. RoseSupreme Court of the United States · 1933
- United States v. KalesSupreme Court of the United States · 1941
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3Cited by3 opinions
- Carroll v. United StatesDistrict Court, S.D. New York · 2001
- Willis v. Department of the Treasury, Internal Revenue ServiceDistrict Court, S.D. New York · 1994
- Diplacido v. CommissionerUnited States Tax Court · 1993