Legal Opinion
Rochelle v. United States
District Court, N.D. Texas
Decided November 15, 1973No. Civ. A. 3-3398 and 3-6146PublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OPINION
WILLIAM M. TAYLOR, Jr., Chief Judge.
These. consolidated suits involve not only identical parties, but also the same essential question: who is entitled to possess an income tax refund of nearly a third of a million dollars. For reasons detailed in the pages that follow, I have decided that the United States acted correctly in setting off the refund against other taxes for which the taxpayer was liable.
The refund 1 on the 1962 Federal income tax of Angus G. Wynne, Jr., and his wife results from a loss carryback from 1964 directly attributable to losses sustained in 1964.…
2Cases cited12 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Lewis v. United StatesSupreme Court of the United States · 1876
- Francis v. McNealSupreme Court of the United States · 1913
- Tucker v. OxleySupreme Court of the United States · 1809
- Gray v. RolloSupreme Court of the United States · 1874
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3Cited by3 opinions
- Still v. United States (In Re W.L. Jackson Manufacturing Co.)United States Bankruptcy Court, E.D. Tennessee · 1985
- Montgomery v. United StatesCourt of Appeals for the Ninth Circuit · 1976
- Danning v. United StatesCourt of Appeals for the Ninth Circuit · 1976