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Robert F. Lundy - Corrected Version - No.94-1785","","Commissioner of Internal Revenue v. Robert F. Lundy, corrected version, presents oral argument before the U.S. Supreme Court on the limits of the tax court’s jurisdiction to award tax refunds. The dispute focuses on how Internal Revenue Code sections 6512(b)(3) and 6511(b)(2) constrain refund amounts and require statutory treatment of refund claims. The record addresses jurisdictional limits, the effect of the notice of deficiency mailing date, and whether refund claims must be filed formally or treated as filed for purposes of the statutes.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/commissioner-of-internal-revenue-v-robert-f-lundy-corrected-version-no94-1785/303044/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/commissioner-of-internal-revenue-v-robert-f-lundy-corrected-version-no94-1785/303044.png","ImageObject",442,249,{"name":88,"@type":89},"นรินทร์","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-06","2026-09-19",true,{"@type":98,"interactionType":99,"userInteractionCount":79},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"What legal issue is the Supreme Court addressing in Commissioner of Internal Revenue v. Robert F. Lundy?","Question",{"text":108,"@type":109},"The case addresses the limitations on the tax court’s jurisdiction to award refunds and how the Internal Revenue Code restricts the refund amounts it may order.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"How does section 6512(b)(3)(B) affect the treatment of a refund claim?",{"text":113,"@type":109},"It limits the tax court’s jurisdiction by requiring the statutes to be applied as if a refund claim had been filed on the relevant date, whether or not it was actually filed.",{"name":115,"@type":106,"acceptedAnswer":116},"Does the tax court require a formal administrative refund claim to award a refund?",{"text":117,"@type":109},"The argument distinguishes tax court from district court by stating that, in tax court, there is no requirement of an administrative claim for the court to award a refund based on overpayment grounds.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},303044,1790205460,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":79,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":135,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":141},2336475104957,"https://ap-avatar.wpscdn.com/avatar/22000c4c6bd8a5076e1?x-image-process=image/resize,m_fixed,w_180,h_180&k=1787554080175789136","OF THE  \nUNITED STATES  \nCAPTION:  COMMISSIONER OF INTERNAL REVENUE.Petitioner v.ROBERT F.LUNDY  \nCASE NO:  \nNo.94-1785  \nPLACE:  \nWashington,D.C.  \nDATE:  \nMonday,November 6,1995  \nPAGES:  \n1-55  \nCORRECTED VERSION  \nALDERSON REPORTING COMPANY111114TH STREET,N.W.  \nWASHINGTON,D.C.20005-5650  \n202289-2260  \n.69 N-4 P2:24  \nSUPRME COURT.U.S  \nMAR5HA,3治CE  \nRFCEIVE  \n1IN THE SUPREME COURT OF THE UNITED STATES  \n2-  -  -  -  -  -  -  -  -X  \n3COMMISSIONER OF INTERNAL  \n4REVENUE,CORRECTED VERSION  \nPetitioner  \n5  \n6  \nNo.94-1785  \nV.  \n7ROBERT F.LUNDY  \n8  \n-X  \n9Washington,D.C.  \n10Monday,November 6,1995  \n11The above-entitled matter came on for oral  \n12argument before the Supreme Court of the United States at13     10:02 a.m.  \n14 APPEARANCES:  \n15KENT L.JONES ESQ.,Assistant to the Solicitor General,  \n16Department of Justice,Washington,D.C.;on behalf of17the Petitioner.  \n18GLENN P.SCHWARTZ,ESQ.,Chicago,Illinois;on behalf of19the Respondent.  \n20  \n21  \n22  \n23  \n24  \n25  \nALDERSON REPORTING COMPANY,INC.1111 FOURTEENTH STREET,N.W.SUITE 400  \nWASHINGTON,D.C.20005(202)289-2260(800)FOR DEPO  \n11  \n12  \n13  \n14  \n15  \n16  \n17  \n18  \n19  \n20  \n21  \n22  \n23  \n24  \n25  \n22  \n1P R O C E E D I N G S  \n(10:02 a.m.)  \n2  \n3CHIEF JUSTICE REHNQUIST:  We'll hear argument  \n4now in Number 94-1785,Commissioner of Internal Revenue v.5Robert F.Lundy.  \n6  \nMr.Jones.  \n7ORAL ARGUMENT OF KENT L.JONES  \n8ON BEHALF OF THE PETITIONER  \n9MR.JONES:Mr.Chief Justice and may it please  \n10 the Court:  \n11The tax court is an Article I court of limited12 jurisdiction.  This case concerns the limitations on the13jurisdiction of the tax court to award refunds.  \n14When a taxpayer commences a suit in tax court to15 review an asserted deficiency,the court may then also16 determine whether an overpayment was made.  Section  \n17    6512(b)(3)of the Internal Revenue Code,however,provides18 three detailed jurisdictional limits on the amount of the19 refund that the court may award.  \n20Under section 6512(b)(3)(A),the court may award21 amounts paid after the notice of deficiency is issued.  \n22 Under 6512(b)(3)(C),the court may award amounts for which  \n23 a claim for refund was made before the notice of  \n24 deficiency was issued,but when,as in this case,there  \n25 was neither subsequent payment nor a prior refund claim,  \n3  \nALDERSON REPORTING COMPANY,INC.1111 FOURTEENTH STREET,N.W.SUITE 400  \nWASHINGTON,D.C.20005(202)289-2260(800)FOR DEPO  \n1 section 6512(b)(3)(B),which this case concerns,limits2 the jurisdiction of the tax court to award amounts that3 would be refundable under 6511(b)(2)if on the date the4 notice of deficiency was issued a claim for refund had5 been filed.6In turn,6511(b)(2)allows a refund of amounts7 paid within 3 years prior to the claim for refund only if8 the claim for refund was made within 3 years from the time9 of the taxpayer's return,but when --10QUESTION:  Mr.Jones,in subsection(B)that11 you're referring to it says that no credit or refund will12 be allowed unless it was paid within the period which13 would be applicable under 6511(b)(2)(C),or if on the date14 of the mailing of the notice of deficiency a claim had15 been filed,whether or not filed.  \nNow,that language is just incomprehensible.  \n16  \n17 What does that parenthetical mean?  Does it mean if it18 isn't filed we can deem it to have been filed?  \n19  \nMR.JONES:  That's --what it means is that,  \n20 whether or not a claim for refund had actually been filed,  \n21 the court is to apply these statutes as if a claim for  \n22 refund was filed on that date.  That was --no one has  \n23 doubted,I think,that that is the meaning of that  \n24 provision.  \n25  \nQUESTION:  And is that what should be done in  \n4  \nALDERSON REPORTING COMPANY,INC.1111 FOURTEENTH STREET,N.W.SUITE 400  \nWASHINGTON,D.C.20005(202)289-2260(800)FOR DEPO  \n二  \n5  \nALDERSON REPORTING COMPANY,INC.1111 FOURTEENTH STREET,N.W.SUITE 400  \nWASHINGTON,D.C.20005(202)289-2260(800)FOR DEPO  \n1 jurisdiction to consider a ju","cbCaig5VfYuPyPWa","https://ap.wps.com/l/cbCaig5VfYuPyPWa","pdf",12261956,56,"English","# Proceedings\n## Oral Argument and Jurisdictional Limits\n## Questioning on Refund Claim Treatment\n## Discussion of Refund Scope under 6512 and 6511","[{\"question\":\"What legal issue is the Supreme Court addressing in Commissioner of Internal Revenue v. Robert F. Lundy?\",\"answer\":\"The case addresses the limitations on the tax court’s jurisdiction to award refunds and how the Internal Revenue Code restricts the refund amounts it may order.\"},{\"question\":\"How does section 6512(b)(3)(B) affect the treatment of a refund claim?\",\"answer\":\"It limits the tax court’s jurisdiction by requiring the statutes to be applied as if a refund claim had been filed on the relevant date, whether or not it was actually filed.\"},{\"question\":\"Does the tax court require a formal administrative refund claim to award a refund?\",\"answer\":\"The argument distinguishes tax court from district court by stating that, in tax court, there is no requirement of an administrative claim for the court to award a refund based on overpayment grounds.\"}]","Commissioner of Internal Revenue - v. Robert F. Lundy - Corrected Version - No.94-1785 | PDF",1789799770,20]