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8. TAX REFUND ACTIONS

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Introductory Comment

Taxpayers who sue for refunds are entitled to a jury trial. See 26 U.S.C. § 7422. The situations giving rise to such suits are too diverse to provide model instructions for all cases.

Tax refund cases often have narrow fact issues and lend themselves to the use of special verdict forms.

The model instructions offered in this section cover only a few issues specific to tax refund cases.