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
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
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