Legal Opinion

William K. Vancanagan, in His Capacity as Personal Representative of the Estate of Ford Bovey, and Sharon Bovey v. United States

Court of Appeals for the Federal Circuit

Decided October 17, 2000No. 99-5040PublishedCited by 25 opinions

1Opinion of the Court

FRIEDMAN, Senior Circuit Judge.

This appeal challenges a decision of the United States Court of Federal Claims that when the appellants filed an application for an automatic extension of time to file their federal income tax return, the money they remitted to the Internal Revenue Service (“IRS”) with their application was a “payment” of their expected tax liability and not a “deposit” to cover such liability. The effect of that ruling was to invalidate as untimely their claim that they had overpaid their taxes. The court therefore dismissed their refund suit. We affirm.

I

A. On April 15, 1990,…

2Cases cited10 opinions

  1. Rosenman v. United StatesSupreme Court of the United States · 1945
  2. New York Life Insurance Company v. United StatesCourt of Appeals for the Federal Circuit · 1997
  3. Baral v. United StatesSupreme Court of the United States · 2000
  4. David F. Ertman and Jane Ertman v. United StatesCourt of Appeals for the Second Circuit · 1999
  5. James R. Cohen and Joanne D. Cohen v. The United StatesCourt of Appeals for the Federal Circuit · 1993

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3Cited by25 opinions

  1. Boensel v. United StatesUnited States Court of Federal Claims · 2011
  2. Dumont v. United StatesUnited States Court of Federal Claims · 2009
  3. Murdock v. United StatesUnited States Court of Federal Claims · 2012
  4. Diamond v. StatesUnited States Court of Federal Claims · 2012
  5. Deaton v. CommissionerCourt of Appeals for the Fifth Circuit · 2006

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

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