Becton Dickinson And Company v. Reinhard A. Wolckenhauer

How courts have described this case

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

• noting the Brock-amp court’s skepticism of equating a tax refund suit with a private restitution suit
• noting the grouping of tax statutes of limitations in Chapter 66, titled “Limitations,” of Title 26 of the United States Code and holding that this statutory scheme does not express an intent to allow equitable tolling
• “In comparing the time limitation at issue in Irwin with the time limitation at issue in this case, it is clear that were we to apply the rule of equitable tolling to suits against the government brought under section 7426(a)(1
• barring application of equitable tolling in wrongful levy action
• “Were we to hold that section 6532(c) can be equitably tolled, we would delay the final disposition of competing claims in cases like this one and would jeopardize, perhaps even destroy, the IRS’s ability to impose a levy on other assets owned by a delinquent taxpayer.”
• “Were we to hold that section 6532(c) can be equitably tolled, we would delay the final disposition of competing claims in cases like this one and would jeopardize, perhaps even destroy, the IRS’s ability to impose a levy on other assets owned by a delinquent taxpayer.”

Source: CourtListener parenthetical corpus (CC0).