1. Home
  2. Browse Decisions
  3. F.3d
  4. 383 F.3d
  5. 383 F.3d 1187 (2004)
 

SORRENTINO v. I.R.S.

Nos. 02-1114, 02-1137.

383 F.3d 1187 (2004)

Rolly J. SORRENTINO; Joann M. Sorrentino, Husband & Wife, Plaintiffs-Appellees, v. INTERNAL REVENUE SERVICE; United States of America, Defendants-Appellants. Steven G. Sklaver, Amicus Curiae.

United States Court of Appeals, Tenth Circuit.

September 14, 2004.

Attorney(s) appearing for the Case

Rolly J. Sorrentino and Joann M. Sorrentino, Pro Se.

Robert W. Metzler, Attorney, Tax Division (Eileen J. O'Connor, Assistant Attorney General and Kenneth L. Greene, Attorney, Tax Division, Department of Justice, Washington D.C., and John W. Suthers, United States Attorney, Denver, CO, with him on the brief), Department of Justice, Washington D.C., for Defendants-Appellants.

Steven G. Sklaver of Cooley Godward LLP, Broomfield, CO, as Court-Appointed Amicus Curiae.

Before SEYMOUR, BALDOCK, and HARTZ, Circuit Judges.

BALDOCK, Circuit Judge, delivering the Judgment of the Court and an Opinion.

Internal Revenue Code (I.R.C.) § 7422(a) authorizes a taxpayer to commence a tax refund suit against the Government once "a claim for refund or credit has been duly filed" with the Internal Revenue Service (IRS). Section 6511 of the I.R.C. limits the Government's waiver of immunity under § 7422(a) by requiring a taxpayer to file a claim for refund or credit with the IRS within a...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases