Waltner v. United States
| Decision Date | 01 October 2012 |
| Docket Number | No. 12–75.,12–75. |
| Citation | 568 U.S. 886,184 L.Ed.2d 155,133 S.Ct. 319 (Mem) |
| Parties | Steven T. WALTNER, et ux., petitioners, v. UNITED STATES. |
| Court | U.S. Supreme Court |
Petition for writ of certiorari to the United States Court of Appeals for the Federal Circuit denied.
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9 cases
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Meissner v. United States
... ... United States , 115 Fed. Cl. 530, 534 (2014). "[W]hether Page 9 sovereign immunity has been waived and the Court of Federal Claims has jurisdiction over these refund claims depends on whether the taxpayers' submissions to the IRS constitute a claim for refund." Waltner v. United States , 679 F.3d 1329, 1333 (Fed. Cir. 2012), cert. denied , 568 U.S. 886, reh'g denied , 568 U.S. 1044 (2012). Section 7422(a) functions as a waiver of the government's sovereign immunity in tax refund suits. Chi. Milwaukee Corp. v. United States , 40 F.3d 373, 374 (Fed. Cir ... ...
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Albemarle Corp. v. United States
... ... Cir. 2010), cert. denied , 131 S. Ct. 1513 (2011). Stated another way, "[i]n the context of tax refund suits, the United States sovereign immunity is construed narrowly and jurisdiction of the Court of Federal Claims is limited by the Internal Revenue Code, including 26 U.S.C. 7422." Waltner v. United States , 679 F.3d 1329, 1332 (Fed. Cir.), cert. denied , 133 S. Ct. 319, reh'g denied , 133 S. Ct. 688 (2012); see id. at 1332 ("Thus, whether sovereign immunity has been waived and the Court of Federal Claims has jurisdiction over these refund claims depends on whether the ... ...
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Martti v. United States
... ... Cir. 2010), cert. denied , 131 S. Ct. 1513 (2011). Stated another way, "[i]n the context of tax refund suits, the United States sovereign immunity is construed narrowly and jurisdiction of the Court of Federal Claims is limited by the Internal Revenue Code, including 26 U.S.C. 7422." Waltner v. United States , 679 F.3d 1329, 1332 (Fed. Cir.), cert. denied , 133 S. Ct. 319, reh'g denied , 133 S. Ct. 688 (2012); see id. at 1332 ("Thus, whether sovereign immunity has been waived and the Court of Federal Claims has jurisdiction over these refund claims depends on whether the ... ...
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Vir v. United States, 15-73T
... ... Cir. 2010), cert. denied , 131 S. Ct. 1513 (2011). Stated another way, "[i]n the context of tax refund suits, the United States sovereign immunity is construed narrowly and jurisdiction of the Court of Federal Claims is limited by the Internal Revenue Code, including 26 U.S.C. 7422." Waltner v. United States , 679 F.3d 1329, 1332 (Fed. Cir.), cert. denied , 133 S. Ct. 319, reh'g denied , 133 S. Ct. 688 (2012); see id. at 1332 ("Thus, whether sovereign immunity has been waived and the Court of Federal Claims has jurisdiction over these refund claims depends on whether the ... ...
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