United States v. Franks

How courts have described this case

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

• holding that where a claimant “is understandably confused by a second notice of disallowance and acts reasonably” statute of limitations runs from second notice
• holding that, where the IRS mailed two notices of disal-lowance of claims, “the second disallowance notiee ... was, in essence, an agreement to extend the time deadline”
• holding that equitable considerations under Section 6511 are contrary to the statute
• “The cases have consistently held that a new claim founded on the same grounds does not extend the statute of limitations.” (citing B. Altman & Co. v. United States, 69 Ct. Cl. 721, 727, 40 F.2d 781, 784, cert. denied, 282 U.S. 863, 51 S. Ct. 36 (1930
• “The cases have consistently held that a new claim founded on the same grounds does not extend the statute of limitations.” (citing B. Altman & Co. v. United States, 69 Ct. Cl. 721, 727, 40 F.2d 781, 784, cert. denied, 282 U.S. 863, 51 S. Ct. 36 (1930

Source: CourtListener parenthetical corpus (CC0).