Legal Opinion
Jane M. Richards, F/k/a Jane M. Morgan v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided December 15, 1994No. 93-9016PublishedCited by 8 opinions
1Opinion of the Court
BRORBY, Circuit Judge.
Ms. Richards appeals the judgment of the United States Tax Court denying her claim for a refund of taxes withheld in 1987. The narrow issue presented in this ease requires us to interpret two specific sections of the Internal Revenue Code (“the Code”), 26 U.S.C. §§ 6511 and 6512(b)(3)(B), to determine whether Ms. Richards’ refund claim was timely. We have jurisdiction to review a final decision of the tax court under 26 U.S.C. § 7482(a)(1) and we affirm.
BACKGROUND 1
Ms. Richards, an accountant, did not initially file a tax return for the 1987 calendar year. Federal income…
2Cases cited16 opinions
- Erie Railroad v. TompkinsSupreme Court of the United States · 1938
- Caminetti v. United StatesSupreme Court of the United States · 1917
- Commissioner v. McCoySupreme Court of the United States · 1987
- Central Trust Co. v. Official Creditors' Committee of Geiger Enterprises, Inc.Supreme Court of the United States · 1982
- National Collegiate Athletic Association v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1990
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3Cited by8 opinions
- Commissioner v. LundySupreme Court of the United States · 1996
- Astrid E.A. Omohundro, Individually and as the Beneficiary of the Estate of Stuart W. Omohundro v. United StatesCourt of Appeals for the Ninth Circuit · 2002
- Robert F. Lundy v. Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995
- Video Training Source, Inc. v. United StatesDistrict Court, D. Colorado · 1998
- Keeter v. United StatesDistrict Court, E.D. California · 1997
3 more not listed; retrieve them via the Exa API.