United States Fourth Circuit

In a tax dispute involving the application of a time-barred tax liability to a refund, trial court judgment in favor of the IRS is affirmed because the IRS can 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.

Appellate Information

• Decided 03/31/2011
• Published 03/31/2011

Judges

• WILKINSON

Court

• United States Fourth Circuit

Counsel