United States v. Dalm

How courts have described this case

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

• holding that § 7422(a) requires a taxpayer seeking a refund to file a claim for a refund before filing suit to collect the refund
• holding that a two-year limitations period bars recovery regardless of whether the tax is illegally collected
• holding that plaintiffs’ refund suit was barred for failing to file a refund claim with the IRS
• holding that a statute of limitations barred an untimely claim for a federal income tax refund, “regardless of whether the tax is alleged to have been ‘erroneously,’ ‘illegally,’ or ‘wrongfully collected’ ” (citations omitted)
• holding that a taxpayer’s failure to file a timely tax return under 26 U.S.C. § 7422(a) deprived the district court of jurisdiction over the taxpayer’s claim for a tax refund
• holding that equitable recoupment, without more, does not give court jurisdiction over refund claims

Source: CourtListener parenthetical corpus (CC0).