Legal Opinion
Gisele C. Fisher v. United States
Court of Appeals for the Federal Circuit
Decided April 10, 1996No. 95-5118PublishedCited by 22 opinions
1Opinion of the Court
FRIEDMAN, Senior Circuit Judge.
In Lewis v. Reynolds, 284 U.S. 281, 52 S.Ct. 145, 76 L.Ed. 293, modified on other grounds, 284 U.S. 599, 52 S.Ct. 264, 76 L.Ed. 514 (1932), the Supreme Court held that in a tax refund suit, the Internal Revenue Service (IRS) may offset against the refund other taxes that had previously not been assessed, and the assessment of which the statute of limitations barred. The question in this ease, here on appeal from the United States Court of Federal Claims, is whether the same principle permits the offset against a tax refund of previously unassessed interest on an…
2Cases cited16 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- South Corporation and Seal Fleet, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1982
- In Re Mark Anthony Construction, Inc., Debtor. United States of America v. Ian Ledlin, TrusteeCourt of Appeals for the Ninth Circuit · 1989
- Loftin & Woodard, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1978
- Samuel C. Dysart and Alma R. Dysart v. The United StatesUnited States Court of Claims · 1965
11 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- Fisher v. United StatesUnited States Court of Federal Claims · 2006
- Bachner v. CommissionerUnited States Tax Court · 1997
- Cencast Services, L.P. v. United StatesUnited States Court of Federal Claims · 2010
- General Electric Co. v. United StatesUnited States Court of Federal Claims · 2003
17 more not listed; retrieve them via the Exa API.