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Edgar Percy Lewis v. Marshall S. Reynolds, Individually and as Collector of Internal Revenue

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Opinion
52 S. Ct. 264 · Supreme Court of the United States · Feb 15, 1932
Full text
Edgar Percy Lewis v. Marshall S. Reynolds, Individually and as Collector of Internal Revenue
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Parentheticals
stating that the issue in a tax refund suit is taxpayer’s entire tax liability for the year
holding taxpayer must prove entitlement to withheld monies
holding taxpayer must prove entitlement to withheld monies
“The action to recover on a claim for refund is in the nature of an action for money had and received and it is incumbent upon the claimant to show that the United States has money which belongs to him.”