United States Third Circuit

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Cooper v. Commissioner of the Internal Revenue Service, 11-3490

In consolidated appeals in which plaintiff-taxpayers seek redeterminations of their tax liability from the Internal Revenue Service (IRS) and tax refunds from the Virgin Islands Bureau of Internal Revenue (VIBIR), judgment dismissing the claims is affirmed, where: 1) the district courts correctly held that the Tax Court is the only venue for plaintiffs' claims against the IRS because Congress has designated the Tax Court as the only court with jurisdiction to adjudicate a tax prepayment deficiency dispute; and 2) the district court correctly granted the VIBIR's motion to dismiss plaintiff McGrogan's claim because the statute of limitations barred his claims against the VIBIR.

Appellate Information

  • Decided 05/17/2013
  • Published 05/17/2013


  • ROTH


  • United States Third Circuit


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