Victor H. Goulding 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.

• noting that “the fact that the government waited for several years to raise this defense points to waiver”
• noting that “the fact that the government waited for several years to raise this defense points to waiver”
• indicating that arguments presented post-trial and post-decisional briefing are deemed waived because they should have been made “at a much earlier stage in these proceedings”
• holding the IRS waived Treas. Reg. § 301.6402-2(b)(1)’s specificity requirement
• finding waiver where the IRS had considered the merits of the taxpayer’s claim based on an “in-depth investigation” it had performed on a related claim, and declined to challenge the sufficiency of the taxpayer’s claim until two years after the original claim was filed
• IRS may rely on address appearing on the tax return it is auditing, absent clear and concise notification from the taxpayer of an address change

Source: CourtListener parenthetical corpus (CC0).