overpayment
Definitions from Case Law · United States Supreme Court
Definitions from Case Law
From 284 U.S. 281 - Lewis v. Reynolds · 1932Most cited · 1,209 citing opinions
tax refund
An overpayment must appear before refund is authorized. Although the statute of limitations may have barred the assessment and collection of any additional sum, it does not obliterate the right of the United States to retain payments already received when they do not exceed the amount which might have been properly assessed and demanded.
How the Supreme Court has restated “overpayment”
Each Supreme Court definition of “overpayment,” sized by how often later courts cited it. “Change” is measured by wording overlap with earlier definitions — a rough signal, not a semantic judgment.
How often courts cite the cases defining “overpayment”
Court decisions citing the 3 opinions that defined “overpayment” — 1,897 in all, by decade. Counts are citations to the defining cases as a whole, not verified uses of the term. The dip in the most recent years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the latest years.
All 3 definitions, chronological · 1932–1947
any payment in excess of that which is properly due. Such an excess payment may be traced to an error in mathematics or in judgment or in interpretation of facts or law. And the error may be committed by the taxpayer or by the revenue agents. Whatever the reason, the payment of more than is rightfully due is what characterizes an overpayment.
The overpayment which brings § 322(b)(1) into operation occurs whenever the taxpayer has paid an amount over and above his true liability.