United States v. Rawdon

How courts have described this case

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

• noting that the payment of a tax liability on an IRS agent’s terms cannot be involuntary if the payer of the tax could have obtained better advice through the exercise of reasonable diligence
• granting motion to dismiss for lack of jurisdiction because only the taxpayer has standing to sue for a tax refund under § 1346(a)(1).
• rather than pay certain taxes as requested by the IRS, plaintiff had the alternative of protesting a later notice of deficiency in the United States Tax Court
• “In order to maintain an action for the refund of taxes under the Internal Revenue Code, the plaintiff must be the taxpayer who has overpaid his own taxes.” (emphasis added)
• In cases involving the payment of tax liabilities by a third party, “it is fundamental that the plaintiff cannot recover if the payment in issue was voluntary.”
• “Ignorance is never sufficient to consti- tute a ground of relief if it appears that the requisite knowledge might have been obtained by reasonable dili- gence.”

Source: CourtListener parenthetical corpus (CC0).