Legal Opinion
Dr. Clayton H. Smith and Doris Jean Smith v. United States
Court of Appeals for the Fifth Circuit
Decided May 2, 1973No. 72-3519PublishedCited by 18 opinions
1Opinion of the Court
RONEY, Circuit Judge:
In this taxpayer refund suit, plaintiffs’ complaint was dismissed by the District Court because it was not filed within the statutory period of limitations governing' such suits. On appeal, taxpayers contend that the notices of disallowance were insufficient to start the running of the period of limitations. We disagree and affirm.
Taxpayers, husband and wife, timely filed joint federal income tax returns for the years 1948 through 1954 and for 1956. On November 23, 1965, following an audit of those returns, the Commissioner of Internal Revenue and taxpayers agreed, on a…
2Cases cited5 opinions
- Thelma Rosenberg v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Luhring v. GlotzbachCourt of Appeals for the Fourth Circuit · 1962
- A. G. Reeves Steel Const. Co. v. WeissCourt of Appeals for the Sixth Circuit · 1941
- Richard T. Gallion and Audrey R. Gallion v. United StatesCourt of Appeals for the Fifth Circuit · 1968
- Sidney L. Gaynes v. United StatesCourt of Appeals for the Fifth Circuit · 1972
3Cited by18 opinions
- Pierre Boulez v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Pierson v. United StatesDistrict Court, D. Delaware · 1977
- Linda Romano-Murphy v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2016
- Frank Tavano v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
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