Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

Plaintiff appealed an Internal Revenue Service ("IRS") denial of a refund claim after an investigation revealed that plaintiff had so under-reported its 1994 income that there was sufficient tax liability to use up all of the credits in that year. At issue was whether the IRS may recalculate plaintiff's 1994 taxes to defeat a refund claim for 1991 and 1992. The court held that summary judgment was proper where the IRS could recalculate tax liability for a year beyond the statute of limitations in order to determine whether excess tax credits can be carried back to previous years to support a refund.