Legal Opinion

John A. Gabelman v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided June 21, 1996No. 95-1251PublishedCited by 21 opinions

1Opinion of the Court

EDMUNDS, District Judge.

John Gabelman appeals the Tax Court’s decision denying his refund claim. Appellant claims the Tax Court improperly designated his remittance as a tax payment rather than a deposit. For the following reasons, we hereby affirm the decision of the Tax Court.

I

In April of 1987, Appellant John Gabelman filed Form 4868, entitled Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, for 1986. 1 Appellant anticipated that the amount withheld by his employer would not satisfy his income tax liability, hence he included a check in the amount of…

2Cases cited14 opinions

  1. United States v. DalmSupreme Court of the United States · 1990
  2. Rosenman v. United StatesSupreme Court of the United States · 1945
  3. Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
  4. Donald G. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
  5. Francis H. Ameel, Administrator D.B.N. Estate of Mary E. Ameel v. United StatesCourt of Appeals for the Sixth Circuit · 1970

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

3Cited by21 opinions

  1. David F. Ertman and Jane Ertman v. United StatesCourt of Appeals for the Second Circuit · 1999
  2. Boensel v. United StatesUnited States Court of Federal Claims · 2011
  3. William K. Vancanagan, in His Capacity as Personal Representative of the Estate of Ford Bovey, and Sharon Bovey v. United StatesCourt of Appeals for the Federal Circuit · 2000
  4. Troy W. Ott v. United StatesCourt of Appeals for the Ninth Circuit · 1998
  5. Sunoco, Inc. v. Comm'rUnited States Tax Court · 2004

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

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