United States v. Dalm

494 U.S. 596 (1990)

From our private database of 46,100+ case briefs, written and edited by humans—never with AI.

United States v. Dalm

United States Supreme Court
494 U.S. 596 (1990)

Facts

Frances Dalm (plaintiff) was Harold Schrier’s secretary for many years. When Schrier passed away, his brother wanted Dalm to be the administrator of Schrier’s estate. Dalm was paid for her administrative duties by both the estate and the brother. On her taxes, Dalm claimed these payments as gifts and paid the appropriate gift tax. The Internal Revenue Service (IRS) audited Dalm and determined that the gifts should not have been taxed as gifts, but rather as income. Dalm petitioned the tax court for a redetermination. Dalm and the IRS reached a settlement for the income-tax deficiencies. Dalm then promptly filed a claim with the IRS to recover the previously paid gift tax. However, the statute of limitations to bring a claim for an overpaid tax refund had already run. The IRS did not act on Dalm’s claim. Dalm brought suit against the United States government (government) (defendant) in the United States District Court for the Western District of Michigan, seeking a refund. The government filed motions to dismiss and for summary judgment. The district court granted the motions, finding a lack of jurisdiction because the statute of limitation had run. The United States Court of Appeals for the Sixth Circuit reversed, holding that the district court could exercise jurisdiction under a theory of equitable recoupment. The United States Supreme Court granted the government’s petition for certiorari.

Rule of Law

Issue

Holding and Reasoning (Kennedy, J.)

Dissent (Stevens, J.)

What to do next…

  1. 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 745,000 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
  2. 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 745,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,100 briefs, keyed to 987 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.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 745,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,100 briefs - keyed to 987 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership