Supreme Court of the United States
Baral v. United States
February 22, 2000528 U.S. 431
Summary
Justice Thomas delivered the unanimous opinion holding that withholding and estimated income tax remittances are deemed paid on the statutory return due date, without regard to an extension, for purposes of the refund and credit limitations in § 6511. Both of Baral’s remittances were therefore paid on April 15, 1989, outside the applicable look-back period, leaving him entitled to no credit. The Court rejected the argument that payment requires assessment and affirmed the judgment below. It reserved the treatment of remittances not governed by a statutory deemed-payment provision. There were no separate opinions.
Holding
- The payment date governing the statutory look-back period for withholding and estimated income tax remittances.. Under § 6513(b)(1) and (2), Baral’s withholding and estimated income tax remittances were paid on April 15, 1989. Because those payments fell outside the applicable look-back period, the ceiling on his requested credit was zero.
- Whether payment of income tax requires a prior assessment.. Assessment is not a prerequisite to payment of the withholding and estimated income tax remittances at issue.
Docket 98-1667
Cited authorities
- Rev. Proc. 84-58
- 26 U.S.C. § 6511
- 26 C.F.R. §301.6315-1
- 26 C.F.R. §301.6315-1
- 26 U.S.C. § 6513
- 26 U.S.C. § 6501
- 26 U.S.C. § 6611
- 57 Stat. 140
Cited by
- John J. McLaine, Petitioner v. Commissioner of Internal Revenue, Respondent
- James R. Dixon, Petitioner v. Commissioner of Internal Revenue, Respondent; Sharon C. Dixon, Petitioner v…
- Libitzky v. United States
- Harrison, Mark v. United States
- Mission Funding Alpha, Appellee v. Commonwealth of Pennsylvania, Appellant
- Principal Life Insurance Company and Subsidiaries v. United States
- Victoria Lynn Murdock v. United States
- George R. Wertz, Jr. v. United States