Union Pacific Railroad Company v. The 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 “an item raised in litigation but not specifically adverted to in the [original] claim might be permitted if it is found that ... the Commissioner considered that unspecified ground in reaching his decision on the items for which a refund was requested”
• discussing cases in which the ground for refund was subsumed within the language used in the claim
• fully paid refund claim can't be revived by belated amendment after expiration of the period of limitations on the original claim
• fully paid refund claim can’t be revived by belated amendment after expiration of the period of limitations on the original claim
• fully paid refund claim can't be revived by belated amendment after expiration of the period of limitations on the original claim
• purposes of rule to prevent surprise; give adequate notice to Service; and allow Service to correct errors and thereby limit scope of contested issues

Source: CourtListener parenthetical corpus (CC0).