Legal Opinion
F. E. Gooding v. The United States. Elizabeth Gooding v. The United States
United States Court of Claims
Decided April 3, 1964No. 165-59Published
1Opinion of the Court
DAVIS, Judge.
Mr. and Mrs. Gooding have brought these refund suits to regain admitted overpayments of income taxes for 1946. Under the stipulated facts, recovery is time-barred unless the mitigation portion of the Internal Revenue Code of 1954, §§ 1311-1315, or the doctrine of equitable recoupment is applicable.
On August 24, 1946, the Goodings and their minor daughter, who had operated an amusement-park equipment business as partners, transferred their respective interests in the assets former ly used by the partnership 1 to the Gooding Amusement Company, Inc. (a corporation organized on the…
Also in this document: Concurrence.
2Cases cited18 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- United States v. DavisSupreme Court of the United States · 1962
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Gooch Milling & Elevator Co. v. United StatesUnited States Court of Claims · 1948
- Randolph v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1935
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