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Federal Circuit· 4/20/2006

Computervision Corp. v. United States

Citations

  • 445 F.3d 1355
  • 97 A.F.T.R.2d (RIA) 2074
  • 2006 U.S. App. LEXIS 9854
  • 2006 WL 1028581

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 informal claim doctrine did not apply where a suit was brought before plaintiff’s claim was perfected
  • recognizing waiver rule but holding that taxpayer could not avail itself of rule where IRS considered claim after the running of the limitations period
  • explaining that this requirement “is designed both to prevent surprise and to give adequate notice to the [IRS] of the nature of the claim and the specific facts upon which it is predicated, thereby permitting an administrative investigation and determination”
  • explaining that this requirement “is designed both to prevent surprise and to give adequate notice to the [IRS] of the nature of the claim and the specific facts upon which it is predicated, thereby permitting an administrative investigation and determination”
  • noting that this requirement “is designed both to prevent surprise and to give adequate notice to the [IRS] of the nature of the claim and the specific facts upon which it is predicated, thereby permitting an administrative investigation and determination”
  • recounting the legal fictions denominated as “substantial variance” — implied claim, agency waiver, general claim and germane claim — that the courts have constructed to reverse an agency’s decision denying a refund claim

Source: CourtListener parenthetical corpus (CC0).

Judges: Newman, Rader, Dyk

Read full opinion on CourtListener

Cited by

65 cases in this archive cite this case; the 20 most cited are listed.

Cites

51 cases in this archive are cited by this case; the 20 most cited are listed.

Other cases named Computervision Corp. v. United States

2 other CourtListener records share this case name.

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.