James M. Thomas 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.

• recognizing lack of subject-matter jurisdiction for refund suits if the taxpayer has not “filed a claim for refund which the IRS has either rejected or not acted upon in six months”
• with one exception, the district court has no jurisdiction over suits for a refund of penalty amounts paid until the taxpayer has paid the full amount of the contested penalty assessment
• “[T]here is no jurisdiction in the district courts over suits for [a tax] refund . . . until the taxpayer has paid the full amount of the contested . . . assessment.”
• “Ordinarily, there is no jurisdiction in-the district courts over suits for the refund of penalty amounts paid until the taxpayer has paid the fall amount of the contested penalty assessment and has filed a claim for refund which the IRS has either rejected or not acted upon”

Source: CourtListener parenthetical corpus (CC0).