Landrum v. Brookshire

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that documents \which do not.apprise the IRS that the taxpayer is presently seeking a refund do not constitute an informal refund request\
• explaining that the “three components to an informal claim” for refund or credit are that it (1) puts the Commissioner on notice that the taxpayer is asserting a right to a refund or credit for a specific year; (2) describes the legal and factual basis for the claim; and (3
• “In our view, it must be clear that the taxpayer is making a present demand for refund.”
• “In sum, the claim must provide the degree of specificity necessary for the IRS to commence, at that point, an investigation into the claim within the statutory period.”
• “The purpose of an informal claim is to allow the IRS ‘to commence, if it wishes, an examination into the claim.’” (quoting Donahue v. United States, 33 Fed.Cl. 600, 609 (1995))
• “Thus, if Ms. Soderberg [an IRS Senior Team Coordinator for Mobil], who is the primary point of contact between the parties, had the requisite knowledge, we think that her knowledge (actual or constructive

Source: CourtListener parenthetical corpus (CC0).