Jeffrey N. Labonte 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 the Government is not estopped from enforcing procedural re- quirements when it fails to inform a taxpayer of their existence
• declining to decide applicability of equitable estoppel in a wrongful tax levy action because it was clear plaintiff was not entitled to the remedy
• “The United States government may be sued only where Congress has waived its sovereign immunity and the existence of such waiver is a ‘prerequisite for jurisdiction.’ ”
• waiver of sovereign immunity “is a prerequisite for jurisdiction” (quotation marks omitted)
• “[T]he traditional elements of equitable estoppel are: (1) misrepresentation by the party against whom estoppel is asserted; (2) reasonable reliance on that misrepresentation by the party asserting estoppel; and (3) detriment to the party asserting estoppel.”

Source: CourtListener parenthetical corpus (CC0).