Legal Opinion
Fleetboston Financial Corporation v. United States
Court of Appeals for the Federal Circuit
Decided April 19, 2007No. 2006-5032PublishedCited by 10 opinions
1Opinion of the Court
Opinion for the court filed by BRYSON, Circuit Judge; NEWMAN, Circuit Judge, dissents.
BRYSON, Circuit Judge.
This case presents a difficult issue of corporate tax liability. FleetBoston Financial Corporation, through its predecessor BankBoston Corporation, overpaid its reported tax liability for tax years 1984 and 1985. Rather than seek refunds of the reported overpayments, FleetBoston elected to have the overpayment for each of those two years credited to its tax account for the immediately succeeding year. Several years later, the Internal Revenue Service (“IRS”) audited FleetBoston’s tax…
2Cases cited6 opinions
- Computervision Corp. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Avon Products, Inc. v. United StatesCourt of Appeals for the Second Circuit · 1978
- Club Ramon, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1961
- Marsh & McLennan Companies, Inc. And Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2002
- May Department Stores Co. & Subsidiaries v. United StatesUnited States Court of Federal Claims · 1996
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Weber v. CommissionerUnited States Tax Court · 2012
- Goldring v. United StatesCourt of Appeals for the Fifth Circuit · 2021
- Ford Motor Company v. United StatesCourt of Appeals for the Sixth Circuit · 2014
- Comcation, Inc. v. United StatesUnited States Court of Federal Claims · 2007
- Prestop Holdings, LLC v. United StatesUnited States Court of Federal Claims · 2010
5 more not listed; retrieve them via the Exa API.