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United States Vs. Williams
Cites for this judgment
- US Supreme Court
- Apr 25, 1995
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U.S. 527 (1995) October Term, 1994 Syllabus United States V. WilliamsSearch
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surely subjected Williams to a tax, even though she was not the assessed party. Colorado Nat. Bank of Denver v. BedfordSearch
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that parties generally may not challenge the tax liabilities of others, is not unyielding. See, e. g., Stahmann v. VidalSearch
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this question, we may not enlarge the waiver beyond the purview of the statutory language. Department of Energy v. OhioSearch
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intent of Congress, construing ambiguities in favor of immunity. United States v. NordicSearch
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to sue for a refund, and to that issue the strength of Williams' case on the merits is not relevant. 3 See Snodgrass v. UnitedSearch
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Busse 4 See Martin v. UnitedSearch
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to volunteers, a limit that would not have barred Williams because she paid under protest. See Philadelphia v. CollectorSearch
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a)(1) by barring the tardy. See United States v. DalmSearch
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the Government cites our observation in Colorado Nat. Bank of Denver v. BedfordSearch
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open to Williams. Nor would any of the vaunted remedies be available to others in her situation. See, e. g., Martin v. UnitedSearch
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Barris v. UnitedSearch
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Brodey v. UnitedSearch
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Section 1346(a)(1) is a postdeprivation remedy, available only if the taxpayer has paid the Government in full. Flora v. UnitedSearch
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b)(3), the lien on the property is removed in exchange for a new lien, rather than a cash payment. v. FinallySearch
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the Court has allowed a refund action by parties who were not assessed, albeit under a different statute. See Stahmann v. VidalSearch
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and I agree that the rule applies even to determination of the scope of explicit waivers. See, e. g., United States v. NordicSearch
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United States v. AetnaSearch
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Casualty & Surety Co., 338 U. S. 366 , 383 (1949) (quoting Anderson v. HayesSearch
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Flora v. UnitedSearch
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any ambiguity is construed in favor of immunity. United States v. NordicSearch
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a person may not claim an administrative remedy was inadequate if she never sought to invoke it. See, e. g., McGee v. UnitedSearch
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Geo. F. Alger Co. v. PeckSearch
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cf. McCarthy v. MadiganSearch
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citing McKart v. UnitedSearch
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to delinquent taxpayers and lienees analogous to the warnings required in criminal cases by our decision in Miranda v. ArizonaSearch
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see also Atchison, T. & S. F. R. Co. v. BuellSearch
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Syllabus United States V. WilliamsSearch
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Colorado Nat. Bank of Denver v. BedfordSearch
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United States v. NordicSearch
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See Snodgrass v. UnitedSearch
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See Martin v. UnitedSearch
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See Philadelphia v. CollectorSearch
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See United States v. DalmSearch
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Martin v. UnitedSearch
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See Stahmann v. VidalSearch
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Anderson v. HayesSearch
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McGee v. UnitedSearch
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McKart v. UnitedSearch
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Miranda v. ArizonaSearch
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Atchison, T. & S. F. R. Co. v. BuellSearch
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