James R. Cohen and Joanne D. Cohen v. The 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 a remittance was a deposit where the taxpayer received statutory notice of deficiency and paid the full amount proposed, but attached a letter to the IRS contesting liability
• remittance made after notice of deficiency and after untimely assessment held refundable as an overpayment

Source: CourtListener parenthetical corpus (CC0).