Does the mere running of the statute of limitations on assessments preclude a taxpayer's action for refund?
MultiRegion, United States of America
The following excerpt is from Stair v. U.S., 516 F.2d 560 (2nd Cir. 1975):
Other cases have either flatly accepted 11 or flatly rejected 12 the contention that the mere running of the statute of limitations on assessments is sufficient to preclude a taxpayer's action for refund. The considerations upon which the stricter view of estoppel rests were set forth in Lignos v. United States, 439 F.2d 1365, 1368 (2d Cir. 1971);
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