William K. Vancanagan, in His Capacity as Personal Representative of the Estate of Ford Bovey, and Sharon Bovey 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.

• holding that the timeliness requirement in § 6511(a) was satisfied in that case because “the [refund] claim . . . was filed within three years of (actually, on the same date as) the filing of the return”
• finding that the taxpayer’s remittance triggered the statute of limita tions for a refund because the remittance was a payment and not a deposit
• declining to the accept a taxpayer’s re-characterization of a remittance as a deposit five and half years after the remittance was initially tendered
• finding a pre-assessment remittance was not a deposit where taxpayers “did not state that the remittance was a deposit rather than a payment or that they were preserving their right to contest their alleged tax liability”
• finding that “[u]nder Treas. Reg. § 301.6402–3(a
• finding that “[u]nder Treas. Reg. § 301.6402–3(a

Source: CourtListener parenthetical corpus (CC0).