Publication Date: 2019-04-08
Practice Area: Administrative Law | Tax
Industry: Federal Government
Court: U.S. Court of Appeals for the Second Circuit
Judge: Circuit Judge Dennis Jacobs
Attorneys: For plaintiff: For Petitioner‐Appellant: Kendall C. Jones, Eversheds Sutherland (US) LLP, Washington, D.C.
for defendant: For Respondent‐Appellee: Richard E. Zuckerman, Principal Deputy Assistant Attorney General; Joan I. Oppenheimer, Tax Division, on the brief, Ivan C. Dale, Tax Division, United States Department of Justice, Washington, D.C.
For Amici Curiae Federal Tax Clinic at the Legal Services Center of Harvard Law School, Philip C. Cook Low‐Income Taxpayer Clinic, in support of Petitioner‐Appellant: Simona Altshuler, on the brief, T. Keith Fogg, Federal Tax Clinic at the Legal Services Center of Harvard Law School, Jamaica Plain, MA; W. Edward Afield, Philip C. Cook Low‐Income Taxpayer Clinic, Atlanta, GA.
Case Number: 17-3900
Statutory Phrase Extended 'Look Back' to Due Date, Allowing Tax Overpayment's Recovery