§6407 — Date of allowance of refund or credit

4 cases·2 followed·2 cited50% support

The date on which the Secretary first authorizes the scheduling of an overassessment in respect of any internal revenue tax shall be considered as the date of allowance of refund or credit in respect of such tax.

  • Treas. Reg. §Treas. Reg. §301.6407-1 Date of allowance of refund or credit

4 Citing Cases

FOLLOWED Hershal Weber, Petitioner 138 T.C. No. 18 · 2012

Section 6407 provides that a refund or credit is deemed allowed on the date "the Secretary first authorizes the scheduling ofan overassessment,'' and·26 C.F.R.

1981); see also Yagoda v.

1981); see also Yagoda v.

Weber v. Commissioner 138 T.C. 348 · 2012