Lewis v. Reynolds

Decision Date15 February 1932
Docket NumberNo. 115,115
Citation284 U.S. 599,76 L.Ed. 514,52 S.Ct. 264
PartiesEdgar Percy LEWIS et al., petitioners, v. Marshall S. REYNOLDS, Individually and as Collector of Internal Revenue
CourtU.S. Supreme Court

In this cause it is ordered that the following words be deleted from the sixth paragraph, of the opinion announced on January 4, 1932:

'Also that at the time of his last decision he was restricted to consideration of the demand for refund and determination of whether the trustees were entitled to deduct the State inheritance taxes.'

Otherwise the opinion will stand as heretofore announced.

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36 cases
  • Dye v. US
    • United States
    • United States Courts of Appeals. United States Court of Appeals (10th Circuit)
    • August 8, 1997
    ...refund unless he has overpaid his tax." Lewis v. Reynolds, 284 U.S. 281, 283, 52 S.Ct. 145, 146, 76 L.Ed. 293, modified, 284 U.S. 599, 52 S.Ct. 264, 76 L.Ed. 514 (1932) (quoting Lewis v. Reynolds, 48 F.2d 515, 516 (10th Cir.1931)). While the statutes authorizing refunds do not specifically ......
  • Massachusetts Mut. Life Ins. Co. v. United States
    • United States
    • Court of Federal Claims
    • January 30, 2012
    ...the taxpayer bears the burden of proving the amount he is entitled to recover." (citing Lewis v. Reynolds, 284 U.S. 281, modified, 284 U.S. 599 (1932)); Helvering v. Taylor, 293 U.S. at 515 ("Unquestionably the burden of proof is on the taxpayer to show that the Commissioner's determination......
  • Title Ins. Co. v. State Bd. of Equalization
    • United States
    • United States State Supreme Court (California)
    • December 31, 1992
    ... ... than requiring it to plead the defense affirmatively, we should treat this action as in the nature of an action for "money had and received" (Lewis v. Reynolds (1932) 284 U.S. 281, 283, 52 S.Ct. 145, 146, 76 L.Ed. 293, mod. Lewis v. Reynolds (1932) 284 U.S. 599, 52 S.Ct. 264, 76 L.Ed. 514) and ... ...
  • Albemarle Corp. v. United States
    • United States
    • Court of Federal Claims
    • October 20, 2014
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2 books & journal articles
  • Federal Taxation - Timothy J. Peaden, Ben E. Muraskin, and James A. Lawton
    • United States
    • Mercer University School of Law Mercer Law Reviews No. 47-3, March 1996
    • Invalid date
    ...period for refund." 56 F.3d at 1357. 22. 51 F.3d 1012 (11th Cir. 1995). 23. Id. at 1014 (citing Lewis v. Reynolds, 284 U.S. 281, modified, 284 U.S. 599 (1932) (holding that a claim for refund involves the redetermination of the entire tax liability)). 24. Id. at 1015 (citing former 26 U.S.C......
  • THE ROLE OF OFFSET IN THE COLLECTION OF FEDERAL TAXES.
    • United States
    • Florida Tax Review Vol. 25 No. 1, September 2021
    • September 22, 2021
    ...2017) (dismissing challenge to offset of refund to delinquent student loans). (112.)Lewis v. Reynolds, 284 U.S. 282 (1932), modified by, 284 U.S. 599 (1932). (113.)Revenue Act of 1928 [section] 322, 45 Stat. 861 (1928); Revenue Act of 1926 [section] 284, 44 Stat. 66 (1926). (114.)Lewis, 284......

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