Ninth Circuit· 3/13/1985

James M. Thomas v. United States

Citations

755 F.2d 728
55 A.F.T.R.2d (RIA) 1094
1985 U.S. App. LEXIS 29288

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).

Judges: Choy, Sneed, Pregerson

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Cited by

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

Cites

4 cases in this archive are cited by this case.

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