POLUR

v.

BOTEIN ET AL.

Citator

Cited By

• Rosenspan v. United States, 438 F.2d 905 (2d Cir. 1971)
  …, 90 L.Ed. 203 (1946); United States v. LeBlanc, 278 F. 2d 571 (5 Cir. 1960); Burns v. Gray, 287 F. 2d 698 (6 Cir. 1961); James v. United States, 308 F. 2d 204 (9 Cir. 1962). But cf. C. I. R. v. Mooneyhan, 404 F. 2d 522 (6 Cir. 1968), cert. denied, 394 U.S. 1001, 89 S.Ct. 1593, 22 L.Ed.2d 778 (1969); Wills v. C. I. R., 411 F. 2d 537, 540 (9 Cir. 1969). When Congress uses such a non-technical word in a tax statute, presumably it wants administrators and courts to read it in the way that ordinary people wo…
• Markey v. Commissioner OF Internal Revenue, 490 F.2d 1249 (6th Cir. 1974)
  …lace of business in subsequent cases in which a taxpayer accepted employment either permanently or for an indefinite length of time away from the place of his usual abode. E.g., Commissioner v. Mooneyhan, 404 F. 2d 522 (6th Cir. 1968), cert, denied, 394 U.S. 1001, 89 S.Ct. 1593, 22 L.Ed.2d 778 (1960); Ham v. United States, 408 F. 2d 671 (6th Cir. 1969). In Mooneyhan, we held that an American citizen who had accepted employment abroad for an indefinite period of time was not entitled to deduct his living expe…
• Beer v. Commissioner OF Internal Revenue, 733 F.2d 435 (6th Cir. 1984)
  …missioner of a mistake of law.” Automobile Club v. Commissioner of Internal Revenue, 353 U.S. 180, 183, 77 S.Ct. 707, 709, 1 L.Ed.2d 746 (1954). See also Commissioner of Internal Revenue v. Mooneyhan, 404 F. 2d 522, 528 (6th Cir.1968), cert. denied, 394 U.S. 1001, 89 S.Ct. 1593, 22 L.Ed.2d 778 (1969) (“The doctrine of equitable estoppel ... cannot prevent the Commissioner from correcting a mistake of law no matter where respondent was led.”). That the refunds resulted from a mistake of law is clear. It has…