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RICHARDS v. C.I.R.

No. 93-9016.

37 F.3d 587 (1994)

Jane M. RICHARDS, f/k/a Jane M. Morgan, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

Rehearing Denied December 15, 1994.

Attorney(s) appearing for the Case

David M. Kirsch, San Jose, CA, for petitioner-appellant.

Regina S. Moriarty (Michael L. Paup, Acting Asst. Atty. Gen., and Richard Farber with her on the brief), Tax Div., Dept. of Justice, Washington, DC, for respondent-appellee.

Before BALDOCK, McWILLIAMS and BRORBY, Circuit Judges.

BRORBY, Circuit Judge.

Ms. Richards appeals the judgment of the United States Tax Court denying her claim for a refund of taxes withheld in 1987. The narrow issue presented in this case requires us to interpret two specific sections of the Internal Revenue Code ("the Code"), 26 U.S.C. §§ 6511 and 6512(b)(3)(B), to determine whether Ms. Richards' refund claim was timely. We have jurisdiction to review a final decision of the tax court under 26 U.S.C. §...

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