David A. Koss Freya B. Koss 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 under § 1346(a)(1), a taxpayer suing for a tax refund “must pay the full amount of the tax prior to filing the suit”
• finding that taxpayer failed to comply with the requirements of section 6511(d)(2)(A) in seeking a refund for a net operating loss carryback from the tax year 1977 when refund claim was not brought until 1991, ten years after 1981 deadline
• barring refund claim by plaintiffs seeking the “net effect” of a “credit to be applied to the outstanding deficiency”
• “[A] taxpayer filing suit for an income tax refund must pay the full amount of the tax prior to filing the suit.”

Source: CourtListener parenthetical corpus (CC0).