RadioShack Corp. v. United States
Court of Appeals for the Federal Circuit
1Opinion of the Court
GAJARSA, Circuit Judge.
RadioShack Corp. appeals from the partial final judgment of the Court of Federal Claims dismissing RadioShack’s claim for refund of certain 1996 taxes (“1996 claim”) under Rule 12(b)(1) of the Rules of the Court of Federal Claims (RCFC) 1 for lack of jurisdiction. Because we agree with the Court of Federal Claims that the 1996 claim was not timely filed by RadioShack with the IRS pursuant to 26 U.S.C. § 6511(a), that RadioShack had thus not met the requirements of 26 U.S.C. § 7422, and therefore that the court lacked jurisdiction over the 1996 claim, we affirm.
BACKGROUND
2Cases cited17 opinions
- United States v. MitchellSupreme Court of the United States · 1983
- United States v. DalmSupreme Court of the United States · 1990
- United States v. Clintwood Elkhorn Mining Co.Supreme Court of the United States · 2008
- United States v. WilliamsSupreme Court of the United States · 1995
- American Bankers Insurance Group v. United StatesCourt of Appeals for the Eleventh Circuit · 2005
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