Rosenman 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.

• recognizing that estimated sums are held as a deposit in the nature of bond rather than as a payment of taxes
• holding that the Government’s application of a remittance after the taxpayer’s deficiency had been assessed constituted payment of the tax liability, triggering the limitations period for the taxpayer to claim a refund
• stating that “[i]n any responsible sense payment was [] made by the application of the balance credited to the petitioners . . . .”
• discussing the relationship between the statute of limitations and interest provisions of the Code
• interpreting phrase “payment of [ ] tax” in predecessor statute to § 6511(a)
• taxpayer was entitled to return of deposit paid more than three years after the filing of the claim

Source: CourtListener parenthetical corpus (CC0).