# Lee Martin, of the Estate of Esther S. Martin and Trustee of the Esther S. Martin Living Trust v. The United States of America

> Court of Appeals for the Seventh Circuit · January 11, 1988 · 833 F.2d 655

URL: https://www.frixlaw.com/law-library/cases/9476938

## Case

- **Full name:** Lee MARTIN, Executor of the Estate of Esther S. Martin and Trustee of the Esther S. Martin Living Trust, Plaintiff-Appellant, v. the UNITED STATES of America, Defendant-Appellee
- **Court:** Court of Appeals for the Seventh Circuit
- **Decided:** January 11, 1988
- **Citations:** 833 F.2d 655
- **Precedential status:** Published
- **Opinion:** Dissent by Ripple
- **Judges:** Wood, Cudahy, Ripple
- **Cited by:** 41 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9476938

## How later opinions describe it (automated extraction)

- 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

## Opinion text

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.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9476938. Public record. Not legal advice.