Legal Opinion
Exchange and Savings Bank of Berlin v. United States
District Court, D. Maryland
Decided January 31, 1964No. Civ. 14790PublishedCited by 18 opinions
1Opinion of the Court
THOMSEN, Chief Judge.
The government has moved to dismiss this action for the recovery of income taxes paid for the years 1957-58-59, on the ground that it was begun more than two years after taxpayer had filed a written waiver of the requirement that it be mailed a notice of disallowance of its claim for refund.
Sec. 6532, I.R.C. of '1954, as amended by see. 89(b), Technical Amendments Act of 1958, P.L. 85-866, 72 Stat. 1606, titled “Periods of Limitation on Suits” provides:
“(a) Suits by taxpayers for refund.
“(1) General rule. — No suit or proceeding under section 7422(a) for the recovery of…
2Cases cited4 opinions
- United States v. Chicago Golf ClubCourt of Appeals for the Seventh Circuit · 1936
- Pacific Mills v. NicholsCourt of Appeals for the First Circuit · 1934
- Beardsley v. United StatesDistrict Court, D. Connecticut · 1954
- Fajardo Sugar Growers Ass'n v. United StatesCourt of Appeals for the Second Circuit · 1959
3Cited by18 opinions
- John Walsonavich, Individually and Trading as Service Electric Company v. United StatesCourt of Appeals for the Third Circuit · 1964
- Ned Miller and Frances Miller v. The United States of AmericaCourt of Appeals for the Second Circuit · 1974
- Barry I. Fredericks v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1997
- Tonkonogy v. United StatesDistrict Court, S.D. New York · 1976
- Johnson v. State Tax CommissionOregon Tax Court · 1967
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