CONGRESSIONAL COUNTRY CLUB

v.

UNITED STATES

Citator

Cited By

• Russell v. Commissioner OF Internal Revenue, 678 F.2d 782 (9th Cir. 1982)
  …ourt [*787] by her motion for dismissal without prejudice. It was the Tax Court, not Russell, that failed to address all the issues. The Commissioner’s reliance on Bankers’ Reserve Life Co. v. United States, 44 F. 2d 1000 (Ct.C1.1930), cert. denied, 283 U.S. 836, 51 S.Ct. 485, 75 L.Ed. 1448 (1931), is misplaced. In Bankers’ Reserve, a taxpayer who had stipulated to a tax deficiency was held to have had an opportunity to litigate his claim of overpayment. Id. at 1003-04. Admission of a deficiency necessarily…
• Cont'l Petroleum Co. v. United States, 87 F.2d 91 (10th Cir. 1936)
  …n the parties and they cannot litigate the issues anew in a separate action in court. Tait v. Western Maryland Ry. Co., 289 U.S. 620, 53 S.Ct. 706, 77 L.Ed. 1405; Bankers’ Reserve Life Co. v. United States (Ct. Cl.) 44 F.(2d) 1000, certiorari denied 283 U.S. 836, 51 S.Ct. 485, 75 L.Ed. 1448; Brampton Woolen Co. v. Field (C.C.A.) 56 F.(2d) 23, certiorari denied 287 U.S. 608, 53 S.Ct. 12, 77 L.Ed. 529. The taxpayer asserts, however, that the order of redetermination in question was a nullity and does not for…
• Erickson v. The United States, 309 F.2d 760 (Ct. Cl. 1962)
  …Peerless Woolen Mills v. Rose, 28 F. 2d 661, 663 (C.A.5, 1928); Ohio Steel Foundry Co. v. United States, 38 F. 2d 144, 69 Ct.Cl. 158, 162, 165 (1930); Bankers Reserve Life Co. v. United States, 44 F. 2d 1000, 71 Ct.Cl. 279, 286 (1930), cert. denied, 283 U.S. 836, 51 S.Ct. 485, 75 L.Ed. 1448 (1930); Moir v. United States, 149 F. 2d 455, 459 (fn. 7) (C.A.1, 1945); Lenny v. Williams, 143 F.Supp. 29, 33 (N.D.Ohio, 1956); Peerless Woolen Mills, 13 B.T.A. 1119, 1126-1127 (1928). . The Government argues that res…