Baral v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that “the ceiling on [the taxpayer’s] requested credit of $1,175 is zero” under § 6511(b)(2) because no tax was paid during the applicable look-back period
• explaining that the date of payment is determined according to the provisions of § 6513, which set a deemed date of payment for remittances of withholding and estimated income tax on the April 15 following the relevant taxable year
• applying § 6513(a) to claim for refund, holding that “[t]hese remittances are ‘paid’ on the due date of the taxpayer’s income tax return”
• “Because [no taxes] were ‘paid’ within the look-back period ... the ceiling on [petitioner’s] requested credit of $1,175 is zero.”
• remittance by taxpayer of estimated income tax, and remittance by taxpayer’s employer of withholding tax, were “paid” on the due date of petitioner’s income tax return
• income taxes may be “paid” prior to formal assessment of the taxes

Source: CourtListener parenthetical corpus (CC0).