Lee Martin, of the Estate of Esther S. Martin and Trustee of the Esther S. Martin Living Trust v. The United States of America · 833 F.2d 655

holding that “[a] timely sufficient claim for refund is a jurisdic- tional prerequisite to a refund suit”

How later courts described this case

holding that “[a] timely sufficient claim for refund is a jurisdic- tional prerequisite to a refund suit”
noting that knowledge of the claim does not defeat the IRS’ right to require compliance with its regulations
"A timely, sufficient claim for refund is a jurisdictional prerequisite to a refund suit."
insufficient notice to IRS

Written by the judges who cited it.

The opinion

RIPPLE, Circuit Judge,

dissenting.

In my view, the taxpayer’s letter of September 19,1983 was sufficient notice to the Internal Revenue Service that the taxpayer was seeking a refund and of the basis for that claim. The adequacy of this notice is especially clear when one assesses the letter in the context of the overall negotiations between the taxpayer and the government.