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Opinion
235 F.3d 11 · Court of Appeals for the First Circuit · Dec 21, 2000
Full text
United States v. Commonwealth Energy
Seventh Circuit · Feb 17, 2005
U.S. Tax Court · Jul 29, 2002
Parentheticals
observing that Supreme Court precedent holds that taxpayers are “not entitled to the refund money until the date of payment” because the payment could be cancelled “even after a check was signed and mailed” (quoting United States v. Wurts, 303 U.S. 414, 417–18 (1938))
“Using the check-clearing date here both satisfies the rule that we construe statutes of limitations in favor of the Government and provides a certain limitations date by which the Government must abide.”
“Using the check-clearing date here both satisfies the rule that we construe statutes of limitations in favor of the Government and provides a certain limitations date by which the Government must abide.”
