From our private database of 33,800+ case briefs...
Anastasoff v. United States
United States Court of Appeals for the Eighth Circuit
223 F.3d 898 (2000)
On April 13, 1996, Faye Anastasoff (plaintiff) mailed a claim to the Internal Revenue Service (IRS) (defendant) seeking a refund for overpaid taxes paid on April 15, 1993. The IRS received the claim on April 16, 1996. Section 6511(b) of the Internal Revenue Code required taxpayers to submit refund requests within three years of paying the subject taxes. Because Anastasoff’s claim was received three years and one day after she paid her taxes, the IRS denied her claim. Anastasoff argued that, under the mailbox rule codified in § 7502 of the Internal Revenue Code, the IRS should have accepted her claim because the claim was postmarked within the three-year period. In an unpublished opinion, Christie v. United States, No. 91-2375MN (1992), the United States Court of Appeals for the Eighth Circuit had previously held that § 7502 did not apply to refund claims that were mailed just before the three-year period stated in § 6511(b) ran out and were received after the three-year period expired. The district court held that § 7502 did not apply to Anastasoff’s claim. Anastasoff appealed to the Eighth Circuit, arguing that because Christie was an unpublished opinion, the Eighth Circuit was not bound to follow its decision in Christie. To make her argument, Anastasoff cited Eighth Circuit Rule 28A(i), which stated that unpublished opinions did not have precedential value.
Rule of Law
Holding and Reasoning (Arnold, J.)
Concurrence (Heaney, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 605,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 605,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 33,800 briefs, keyed to 984 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.