Legal Opinion
Estate of Pechan v. United States
District Court, E.D. New York
Decided June 14, 1988No. 86 CV 1471Published
1Opinion of the Court
MEMORANDUM AND ORDER
McLAUGHLIN, District Judge.
This is an action under the Internal Revenue Code of 1954, as amended, 26 U.S.C. § 7422, for refund of a tax overpayment. See 28 U.S.C. § 1346(a)(1). Defendants move to dismiss the Complaint for lack of subject matter jurisdiction. Fed.R.Civ.P. 12(b)(1). Defendants move, in the alternative, for summary judgment. Fed.R.Civ.P. 56(b).
FACTS
The parties and this dispute are certainly not strangers to the federal judicial system. Over the past eleven years, the issues in this case have been placed twice before the United States Tax Court, before the…
2Cases cited9 opinions
- Disabled American Veterans v. United StatesUnited States Court of Claims · 1981
- Arch Engineering Company, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1986
- Altman v. ConnallyCourt of Appeals for the Second Circuit · 1972
- Disabled American Veterans v. The United StatesCourt of Appeals for the Federal Circuit · 1983
- Oldland v. KurtzDistrict Court, D. Colorado · 1981
4 more not listed; retrieve them via the Exa API.