Harold D. Curry and Magdalene Curry 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 court lacks jurisdiction because plaintiffs failed to exhaust their claims, but even if they had exhausted, they would be barred from obtaining a refund because of the time requirements under § 6511
• rejecting, albeit not on constitutional grounds, a “hardship” exception to the Flora full payment rule and noting that the plaintiffs had “only them selves and their accountant to blame” for their late filing
• district court had no jurisdiction over taxpayer's refund action where taxpayer had failed to pay assessed tax in full before bringing action
• “Because the Currys are deemed to have paid all the withheld taxes for which they seek refund on April 15, 1976 and April 15, 1977 and these dates are more than three years preceding the July, 1980 date on which they filed for refund, the Currys may not obtain any of the refund sought.”

Source: CourtListener parenthetical corpus (CC0).