Rosenman v. United States

323 U.S. 658 (1945)

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Rosenman v. United States

United States Supreme Court
323 U.S. 658 (1945)

Facts

Louis Rosenman died on December 25, 1933. By law, any amounts determined to be owed as estate taxes were due within one year of Rosenman’s death. On December 24, 1934, the executors of Rosenman’s estate (plaintiffs) remitted $120,000 to the Internal Revenue Service (IRS). Neither the IRS nor the executors had arrived at a calculation of the amount of estate tax owed at that time. Accordingly, the executors’ purpose in making the remittance was not to satisfy a determined estate-tax liability but rather to avoid the running of any interest or penalties for late payment of estate taxes pending the determination of the amount of those taxes. On February 25, 1935, Rosenman’s estate filed an estate-tax return, having determined that the estate ultimately owed approximately $80,000 in taxes. The IRS had not yet completed its audit of the estate’s return and thus had not arrived at its own assessment of the estate’s ultimate tax liability. Accordingly, the IRS told the executors that it had credited $80,000 of the estate’s December 1934 remittance in satisfaction of any assessed taxes, leaving a balance of $40,000. In April 1938, the IRS completed its audit, determining the estate’s overall tax liability to be approximately $130,000, and assessed a deficiency of $50,000. The IRS claimed the balance of the December 1934 remittance, and the executors paid the IRS an additional $10,000 to satisfy the remainder of the deficiency. In May 1940, the executors determined that the estate was entitled to additional tax deductions and filed a refund claim with the IRS for approximately $25,000. The IRS, citing the fact that any refund claim for overpayment of taxes had to be made within three years of the tax payment, rejected the estate’s claim except as it pertained to the $10,000 April 1938 payment. The estate sued the United States government (defendant) for the full refund in the Court of Claims, which held in favor of the government. The estate appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Frankfurter, J.)

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