United States v. Lori Rabin Williams (514 U.S. 527)
U.S. Supreme Court · decided April 25, 1995 · Supreme Court Database (Spaeth)
- Citation
- 514 U.S. 527 · 115 S. Ct. 1611
- Decided
- April 25, 1995
- Term
- October Term 1994
- Vote
- 6–3
- Majority author
- Justice Ginsburg
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Justice Ginsburg delivered the opinion of the Court. This case presents the question whether respondent Lori Williams, who paid a tax under protest to remove a lien on her property, has standing to bring a refund action under 28 U. S. C. § 1346(a)(1), even though the tax she paid was assessed against a third party. We hold that respondent has standing to sue for a refund. Respondent’s suit falls within the broad language of § 1346(a)(1), which gives federal courts jurisdiction to hear “[a]ny civil action against the United States for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected,” and only a strained reading of other relevant provisions would bar her suit. She had no realistic alternative to payment of a tax she did not owe, and we do not believe Congress intended to leave parties in respondent’s position without a remedy. I Before this litigation commenced, respondent Lori Williams and her then-husband Jerrold Rabin jointly owned their home. As part owner of a restaurant, Rabin personally incurred certain tax liabilities, which he failed to satisfy. In June 1987 and March 1988, the Government assessed Rabin close to $15,000 for these liabilities, and thereby placed a lien in the assessed amount on all his property, including his interest in the house. See 26 U. S. C. § 6321 (“If any person liable to pay any tax…
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