PALA, Inc. Employees Profit Sharing Plan & Trust Agreement 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 “courts will excuse ‘harmless noncompliance’ with the formalities prescribed for refund claims,” provided that the taxpayer corrects the formal deficiencies at a later time
• explaining that \courts will excuse harmless noncompliance with the formalities prescribed for refund claims ... predicated on an expectation that these formal deficiencies will at some point be corrected\
• explaining that “courts will excuse harmless noncompliance with the formalities prescribed for refund claims ... predicated on an expectation that these formal deficiencies will at some point be corrected”
• noting “PALA could have filed a protective claim for a refund as early as 1994,” prior to expiration of time-limits, to preserve claim
• noting Congress’s waiver of sovereign immunity for certain tax refund suits
• “The fact that PALA’s letter does not specifically mention the year 1991 is irrelevant .... ”

Source: CourtListener parenthetical corpus (CC0).