Legal Opinion
Doughty v. United States
District Court, D. Montana
Decided February 27, 1969No. 1637PublishedCited by 1 opinion
1Opinion of the Court
ORDER AND OPINION
RUSSELL E. SMITH, Chief Judge.
In this action for a tax refund the parties have, by a stipulation which contains the agreed facts, submitted two issues to the Court.
I
Whether the Court has jurisdiction to consider the claim of a'person who did not, prior to the commencement of this action, file a claim for refund with the Internal Revenue Service.
The plaintiffs are assignees of a right to recover a claimed overpayment in federal estate tax. Three of the assignees filed timely claims for refund for their portion of the claim. The fourth, Paul Moran, did not file a claim. In the…
2Cases cited6 opinions
- United States v. StapfSupreme Court of the United States · 1964
- Dorothy Jane Dougherty and Louis F. Baldwin, Executors of the Estate of Allen P. Jackson v. United StatesCourt of Appeals for the Sixth Circuit · 1961
- Estate of Sol Schildkraut, Deceased, Eugene Schildkraut and Lester Schildkraut, Executors v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Meyer v. United StatesSupreme Court of the United States · 1960
- Stephens v. United StatesDistrict Court, D. Montana · 1967
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Estate of Montgomery v. CommissionerUnited States Tax Court · 1988