Legal Opinion

Robb Evans & Associates, LLC v. United States

Court of Appeals for the First Circuit

Decided March 3, 2017No. 15-2540PPublishedCited by 33 opinions

1Opinion of the Court

SELYA, Circuit Judge.

These appeals require us to construe and apply 26 U.S.C. § 1341(a), reproduced in the Appendix, a statutory provision that addresses the situation of a taxpayer who pays taxes on income that she must later restore because it is established in a subsequent year that she did not have an unrestricted right to the income. The statute permits such a taxpayer to reduce her tax liability for the year of repayment by the amount that her taxes in the year of inclusion would have decreased had the restored funds been excluded from her income in that year. But there is a catch: by…

2Cases cited41 opinions

  1. Connecticut National Bank v. GermainSupreme Court of the United States · 1992
  2. United States v. Ilario M.A. ZanninoCourt of Appeals for the First Circuit · 1990
  3. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  4. Taylor v. SturgellSupreme Court of the United States · 2008
  5. Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984

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3Cited by33 opinions

  1. Patton v. JohnsonCourt of Appeals for the First Circuit · 2019
  2. Vargas-Colon v. Fundacion Damas, Inc.Court of Appeals for the First Circuit · 2017
  3. Axia NetMedia Corp. v. Mass. Technology Park Corp.Court of Appeals for the First Circuit · 2018
  4. United States v. SaccocciaCourt of Appeals for the First Circuit · 2021
  5. Zucker v. RodriguezCourt of Appeals for the First Circuit · 2019

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