Northern States Power Company, a Minnesota Corporation, and Northern States Power Company, a Wisconsin Corporation 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 26 U.S.C. § 6402 gives the IRS the discretionary authority to credit tax overpayments to any tax liability
• stating that analysis starts and ends with a straightforward and clear statute
• agreeing, prior to the passage of § 6621, that IRS couldn’t balance net—and therefore interest net—after a taxpayer had “paid off its tax deficiencies”
• “[T]he IRS may credit an overpayment against an outstanding liability, and if it does, Section 6601(f)’s netting provision comes into play.”
• “In a proper case, the failure to credit overpayments might be reviewable on an abuse-of-discretion basis”
• \[ Section 6402 ] 'plainly gives the IRS the discretion to apply overpayments to any tax liability.'\ (quoting United States v. Ryan (In re Ryan) , 64 F.3d 1516 , 1523 (11th Cir. 1995))

Source: CourtListener parenthetical corpus (CC0).