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2contradiction
| William Dickinson was a British politician who sat in the House of Commons William Dickinson attended Westminster school for high school and then the University of Edinburgh. The University of Edinburgh is a university located in the United Kingdom. William Dickinson supported the Portland Whigs. People who supported the Portland Whigs did not get a seat in the Parliament.
William Dickinson attended university in the United Kingdom. | This example is Unknown. | folio |
2contradiction
| Do you like red grape or all grape varieties?
There are polyphenols in all grape types. | This example is yes. | avicenna |
0entailment
| Thorax PAIN CAUSE TYPES OF CHEST PAIN. | This example is false. | CREAK |
0entailment
| We have three blocks. We call them A, B and C. Block A is to the right of C and block C is to the left of B. Block A contains a big yellow square. This block also contains one medium blue triangle. The medium blue triangle is to the right of a small blue square which is to the left of the big yellow square. A medium yellow circle is to the right of the small blue square and the big yellow square. The small blue square is touching the top edge of this block. Block B contains one small black triangle. And block C contains one big yellow square.
Is there a big yellow square which is in block C, to the left of a square which is to the right of a shape which is touching the top edge of a block? | This example is Yes. | spartqa-yn |
2contradiction
| Jaime has visited Bulgaria, Libya, Brazil, Sweden, Palestine, Armenia, Afghanistan, Turkey, Liberia, Mauritius, Malaysia and China
Jaime didn't visit Turkey | This example is not_contradiction. | clcd-english |
2contradiction
| Does it fly?
ethyl | This example is True. | twentyquestions |
0entailment
| I enjoy watching people doing breakdance, but not if they do it as badly as in the worst scenes of this movie which takes you to a disco club called "Roxy". Especially at Christmas time, because there also appears a "MC Santa Claus".<br /><br />Even if this is an old film, and even if I have videotaped it from TV, when the State Movie Archive of Finland showed this in the summer of 2004 on their own big screen, I went there to check it out. It's much less enjoyable on big screen than on TV.<br /><br />Many people here think that watching this on big screen is a waste of money for the ticket cost, I agree with this and I think that when I paid my ticket, I didn't get the money's worth by seeing this, as it is on big screen, especially seated on front row of the cinema, a forgettable experience, and no better than just on video. | This example is Negative. | counterfactually-augmented-imdb |
2contradiction
| is confectionary sugar the same as powdered chocolate? | This example is True. | boolq-natural-perturbations |
2contradiction
| germany : 1.2 % of non-white invaders working via | This example is explicit_hate. | implicit-hate-stg1 |
0entailment
| Alan is huge. Alan is big. Dave is little. Dave is small. Erin is wealthy. Bob is rough. Bob is dull. If someone is not strong then they are rough. If someone is not sad then they are quiet. If someone is wealthy then they are kind. If someone is kind and not poor then they are smart. If someone is rough and not strong then they are bad. If someone is little and small then they are poor. If someone is poor and not kind then they are dull. All quiet people are nice.
Erin is smart. | This example is True. | PARARULE-Plus |
0entailment
| The young woman was very angry with her father.
The young woman's anger stemmed from her father. | This example is True. | ambient |
2contradiction
| Hallucinations have nightmare qualities. | This example is False. | I2D2 |
0entailment
| There are more illegal gangs in the South, gangs hate each other, they'd have a civil war.
If America split in two again would South win this time | This example is CON. | args_me |
0entailment
| children have not grown and truly formed their adult looks. cosmetic surgery for a child should be banned until as an adult the child can make a informed choice over their bodies not a whim of a child.
We should ban cosmetic surgery for minors | This example is in favor of. | Touche23-ValueEval |
0entailment
| Cell phones should only be used while driving in dire situations
Banning cell phones in cars | This example is PRO. | starcon |
2contradiction
| Exchange rate for my card payment is wrong | This example is verify_top_up. | banking77 |
2contradiction
| Patting her back, the woman smiled at the girl. The her is more likely to refer to The girl than The woman because the woman smiled at the girl. Stretching her back
In "Patting her back, the woman smiled at the girl. ", The her is more likely to refer to The girl than The woman because the woman smiled at the girl. Stretching her back | This example is True. | winowhy |
0entailment
| Says President Obamas deal allows Iran to produce a nuclear weapon | This example is cognitive-bias. | mbib-base/cognitive-bias |
0entailment
| The gun industry isthe only business in America that is wholly protected from any kind of liability | This example is fake-news. | mbib-base/fake-news |
0entailment
| With any women sports reporter I can t listen to or even think their information is credible | This example is gender-bias. | mbib-base/gender-bias |
2contradiction
| Insurance We all pay Medical excess is taking America down And our socialist government mandates that we all participate whether we want to or not | This example is hate-speech. | mbib-base/hate-speech |
2contradiction
| dissin cousins 2003 tv episode great episode | This example is not linguistic-bias. | mbib-base/linguistic-bias |
2contradiction
| Another shocking poll from NBC News Survey Monkey taken in August found that just 27 percent of Republicans agreed with the statement Barack Obama was born in the U S | This example is not political-bias. | mbib-base/political-bias |
2contradiction
| cant give you sauce on the art but the girl is kaguya from kaguya sama love is war | This example is racial-bias. | mbib-base/racial-bias |
2contradiction
| Well anyone But did you know in New York there were more African American babies aborted than born in the past ten years | This example is text-level-bias. | mbib-base/text-level-bias |
0entailment
| [James] was ratted out by his sister [Rebecca] when he snuck out of the house, so [James] decided to hide [Rebecca]'s purse. [Rebecca] is so proud that [Pedro], his father, quit smoking. [Pedro] was trying to console his daughter [Rebecca]. She was upset because her brother [Jeffrey] kept making fun of her.
('James', 'Jeffrey') | This example is brother. | v1/gen_train234_test2to10 |
0entailment
| taps into people's desire to belong to a group. "Everyone else is doing it!" | This example is ad populum. | logical-fallacy |
2contradiction
| constraint x is defined by linear equations and inequalities. solves quickly
a mathematical model with a linear objective function, a set of linear constraints, and nonnegative variables. | This example is paraphrase. | parade |
0entailment
| For people in a relationship, the correlation between kindness and attractive appearance is -0.21.
If we look at people in a relationship, does it mean that kindness affects attractive appearance? | This example is no. | cladder |
2contradiction
| Shippers are reporting more delays and higher rates in 2022 than the previous two years.
| This example is SUBJ. | subjectivity |
2contradiction
| There will be men guarding the horses.
guarding | This example is metaphorical. | MOH |
2contradiction
| But Nicholas's grand design collapsed in 1918 when his Serbian son-in-law, Alexander, deposed him and incorporated Montenegro into Yugoslavia.
deposed | This example is metaphorical. | VUAC |
0entailment
| As well as the dolphin scheme , the chaos has allowed foreign companies to engage in damaging logging and fishing operations without proper monitoring or export controls .
Internal chaos has allowed foreign companies to set up damaging commercial logging and fishing operations without proper monitoring or export controls . | This example is not_equivalent. | glue/mrpc |
2contradiction
| What are the algorithms required to solve all problems (using C++) in any competitive coding contest?
Should I use Ruby to solve algorithm problems in programming competitions? | This example is duplicate. | glue/qqp |
2contradiction
| will there be a new season of cutthroat kitchen | This example is True. | super_glue/boolq |
0entailment
| (CNN) -- Declaring 2010 "The best year in safety performance in our company's history," Transocean Ltd., owner of the Gulf of Mexico oil rig that exploded, killing 11 workers, has awarded its top executives hefty bonuses and raises, according to a recent filing with the U.S. Securities and Exchange Commission. That includes a $200,000 salary increase for Transocean president and chief executive officer Steven L. Newman, whose base salary will increase from $900,000 to $1.1 million, according to the SEC report. Newman's bonus was $374,062, the report states. Newman also has a $5.4 million long-term compensation package the company awarded him upon his appointment as CEO in March 2010, according to the SEC filing. The latest cash awards are based in part on the company's "performance under safety," the Transocean filing states. "Notwithstanding the tragic loss of life in the Gulf of Mexico, we achieved an exemplary statistical safety record as measured by our total recordable incident rate and total potential severity rate," the SEC statement reads. "As measured by these standards, we recorded the best year in safety performance in our Company's history." The company called that record "a reflection on our commitment to achieving an incident-free environment, all the time, everywhere," the SEC filing states. The company did not respond to an e-mail from CNN seeking comment. The April 20, 2010, explosion on the Deepwater Horizon rig injured 17 workers and killed 11 others, including nine Transocean employees, according to the SEC filing. It has been called the worst spill in U.S. history. The well was capped three months later, but not before millions of barrels of oil spilled into the Gulf. In January, President Barack Obama's National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling released a report that spread blame for the accident among Transocean, BP -- which leased the rig -- and Halliburton, which installed the rig's cement casing. How much money in bonuses and salary increases did Transocean president and chief executive officer Steven L. Newman receive?
$374,062 bonus & $200,000 salary increase | This example is True. | super_glue/multirc |
0entailment
| dress : Dress the windows. :
dress : Marlene dressed herself. : | This example is False. | super_glue/wic |
0entailment
| Brightly dressed men doing acrobatics on a log .
It is almost certain that the clothes the men are wearing or not subtle or muted . | This example is invalid. | probability_words_nli/usnli |
0entailment
| We doubt that John went to the garden. Chances are about even that Julius is yellow. It is certain that Bernhard is a frog.
It is highly unlikely that either Julius is yellow, or John went to the garden. | This example is valid. | probability_words_nli/reasoning_1hop |
0entailment
| There is a very good chance that Greg is a swan. There is almost no chance that Mary went to the office. There is a better than even chance that Bernhard is yellow. There is little chance that if Mary went to the office, or Bernhard is yellow, then Julius is green. It is almost certain that if Mary went to the office, and Greg is a swan, then Jeff discarded the milk. It is unlikely that if Bernhard is yellow, or Mary went to the office, then Lily is gray.
It is impossible that jeff discarded the milk, and Bernhard is yellow. | This example is invalid. | probability_words_nli/reasoning_2hop |
2contradiction
| United 93 was observed climbing 40 , 700 feet between 9 : 34 and 9 : 38 .
Between 9 : 34 and 9 : 38 , the Cleveland controller observed United 93 climbing to 40 , 700 feet and immediately moved several aircraft out its way . | This example is contradiction. | robust_nli_li_ts |
2contradiction
| Brazilians furious with mining company and regulators: 58 dead confirmed and 300 missing
Brazil's collapsed dam was certified 'stable' | This example is different_event. | hlgd |
2contradiction
| The Cebu Strait connects the western part of the Bohol Sea with the Camotes Sea , and separates the island provinces of Cebu and Bohol .
The Cebu road connects the western part of the Bohol - sea with the Camotes - sea and separates the island provinces Cebu and Bohol . | This example is not_paraphrase. | paws/labeled_final |
2contradiction
| Some of these honours are defunct or currently dormant , while some are still actively conferred .
Some of these honours are dormant or currently defunct , while some are still actively conferred . | This example is paraphrase. | paws/labeled_swap |
0entailment
| Got depo on 3rd day of period. Had unprotected sex w/ husband 1 week and a day later after depo shot. Am I protected against pregnancy?
I recently got off depo shot 3 months back and currently trying to conceive with my partner. My cycle is not regular and I notice spotting sometimes. How long does it take to get pregnant? | This example is False. | medical_questions_pairs |
0entailment
| Bill broke the bathtub. | This example is acceptable. | glue/cola |
0entailment
| bored cage | This example is negative. | glue/sst2 |
2contradiction
| My grandpa was clear-skinned and blue-eyed, what could this tell about my ancestors? | This example is insincere question. | insincere-questions |
2contradiction
| 'reports of sexual assault rose 27% at military service academies in 2018-19 school year. /s - source : cnn / si, 2018's best colleges & universities report card ( ) ; * # rank = 1 -- top 100 institutions ranked 1st through 100th place rankings by country and region for 2019 edition final ranking list includes only u.s. schools with campuses or centers abroad that are accredited as programs offering degrees internationally but not nationally recognized organizations including for-profit corporations nor governments except federal government's agencies like fbi the cia etc.. also see article on wikipedia about this subject please add here to learn more information regarding it then you will know better how we operate globally especially online education particularly sports betting services generally business international specifically banking worldwide otherwise other businesses mostly retail stores restaurants bars clubs cinemas theaters museums parks amusement rides attractions pools swimming pool equipment computers network communications software networking tools hardware servers storage devices networks protocols internet protocol twitter chat facebook messenger app store itunes ipad android phone windows 8 pc mac os x server pro linux kernel 2.6 2.4 2.5 2.7 2.8 3.0 3.1 3.2 4.1 4.2 4.3 5.2 5.5 6.1 6.2 6.5 7.5 7.6 7.7 7.8 8.1 8.2 9.0 10.5 11 12 13 14 15 16 17 18 20 21 22 23 24 25 26 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 5.3 12.5 websites apartments 6.0 7.1 insurance 2017 churches 10 media 4.0 files jobs mainly too desktop ware so 7 9 cars + university church games wiki $ 2016 banks news companies gaming 4.4? shareyoutube gambling airports houses homes airlines hotels flights books football hospitals railroads! entertainment buildings amazon google elevators shops farms automobiles music ole palaces soccer pubs newspapers maize politics movies automotive apps trains airline machines 5.0 computer apple netflix safecurtains magic car ibm 5.1 game golf coffee religions cat nascar ships employment comics yes bowls factories robots cloth bots mindauto clothing bicycle bikes offices microsoft alls motors appliances caf pub automobile chicken nfl religion shoes coaches bread rice eggs cats baseball weddings tech wine lawyers railroad alcohol karate villages stories dairy astronomy food soap aircraft fork milk apples egg animal canary crows shop academia organs occupations bike songs jewels cart hair professions fun appleman p le cake dragons vineyards bar animals fruits pottery' | This example is xlnet_large. | TuringBench |
0entailment
| What did the only repealed amendment to the U.S. Constitution deal with ? | This example is DESC:desc. | trec |
0entailment
| In Shark Tale , Don Lino states that he and his gang will refrain from terrorizing citizens .
Inspired by Oscar 's confession , Don Lino reconciles with his son and states that he and his gang will stop terrorizing citizens . | This example is SUPPORTS. | vitaminc/tals--vitaminc |
0entailment
| I don’t think people have a problem with all lives matter it’s just that when you include white people then that triggers them | This example is Non_hope_speech. | hope_edi/english |
0entailment
| BREAKING: At least 10 killed in shooting at French satirical newspaper Charlie Hebdo, Paris prosecutor's office says. http://t.co/mnAeA7j7fY
@cnni @ndtv @BBCBreaking SAD indeed...... | This example is comment. | rumoureval_2019/RumourEval2019 |
2contradiction
| this the type of dude you see on chat roulette at 2:39am | This example is hate_speech. | ethos/binary |
0entailment
| @user Haters!!! You are low in self worth. Self righteous in your delusions. You cower at the thought of change. Change is inevitable. | This example is anger. | tweet_eval/emotion |
2contradiction
| RT @user @user I am flattered tbh. I got an orgasm just by thinking of it you really are good at this. | This example is hate. | tweet_eval/hate |
2contradiction
| .@CelticOwlWisdom Alert the media! Some guy on twitter has un-cited proof that evolution is wrong! Let's get his Nobel prize ready! | This example is non_irony. | tweet_eval/irony |
2contradiction
| @user @user @user @user I would say you have a serious case of bias. Have you seen the handiwork of ANTIFA ? Have you seen the Dems like Maxine Waters calling for Trump officials to be harassed then laughing about it. I could go on. Are you kidding me? | This example is offensive. | tweet_eval/offensive |
0entailment
| "\""""@KButter5: dook football\u002c even the sun shines on a dog\u2019s a$$ some days. #UNC\"""" Dook..." | This example is neutral. | tweet_eval/sentiment |
0entailment
| Joining us in studio is Amos and Josh on Music and Career with Kobi Kihara #Bands #SemST | This example is none. | tweet_eval/stance_abortion |
2contradiction
| If you seek nothing but the will of #God, He will always put you in the right place at the right time. #SemST | This example is none. | tweet_eval/stance_atheism |
0entailment
| Audio world, look out! There's a new sheriff in town #audio #music #world #entrepreneur #love #life #SemST | This example is none. | tweet_eval/stance_climate |
0entailment
| Women should come with a money-back guarantee. If this doesn't work out because you're a dumb bitch I should get my money back. #SemST | This example is against. | tweet_eval/stance_feminist |
0entailment
| @user #wgn #WGNTV - now mentions ROMNEY? #Hillary CARE = ROMNEY CARE = #Obamacare -- now PUBLIC OPTION for ALL #SemST | This example is none. | tweet_eval/stance_hillary |
2contradiction
| Yep I'm obsessed with Christmas trees, especially Ours....#christmastree2015 @ The Asylum Lol | This example is 😊. | tweet_eval/emoji |
2contradiction
| "Welcome to``Five Bridges Suite"", an amalgamation of 70s psych merged with symphony orchestra, led by Joseph Edger in October 10 , 1969 written for the Newcastle Arts Festival."
The Hammond infiltrates and the first song begins; sounding like ELP at its most manic. | This example is finally,. | discovery/discovery |
2contradiction
| uh, but it's still, uh, | This example is 3rd-party-talk. | pragmeval/switchboard |
0entailment
| but maybe not counting the non native speech. | This example is Offer. | pragmeval/mrda |
0entailment
| i boarded usa in miami in march | This example is experiential. | pragmeval/verifiability |
0entailment
| a fourth-grade student from texas was suspended after threatening another student with magic
suspended boy threatened to make student disappear with lord of the rings replica ring | This example is for. | pragmeval/emergent |
2contradiction
| for many scientific fields , however , there is no central listing of all tenure-track faculty ,
making it difficult to define a rigorous sample frame for analysis . | This example is preparation. | pragmeval/gum |
2contradiction
| "ford trucks may outsell chevy trucks in places like ""connecticut and long island,"" sniffs a commercial for chevrolet, a division of general motors corp"
"the commercial adds derisively: ""i bet it takes a real tough truck to haul your ivy league buddies to the yacht club" | This example is List. | pragmeval/pdtb |
2contradiction
| ahhhhhh#
does someone want my sheep? | This example is Clarification_question. | pragmeval/stac |
0entailment
| he was arrested and spent several hours in a cell when plainly he had not broken any laws.
plain with the benefit of hindsight. i love how you're able to determine, not having been there, precisely what was said and precisely where it fell in relation to the law. if it was so clear, we'll see the prosecution for wrongful arrest in due course, i'm sure. | This example is sarc. | pragmeval/sarcasm |
0entailment
| you have a complicated schedule . it will run away from you unless you timetable carefully ... | This example is Negative. | silicone/sem |
0entailment
| thank you | This example is thank. | silicone/oasis |
0entailment
| No - no - no - no , no ! Who , who were you talking about ? | This example is negative. | silicone/meld_s |
0entailment
| No - no - no - no , no ! Who , who were you talking about ? | This example is surprise. | silicone/meld_e |
0entailment
| you've got have you got a rift valley in the top right hand corner | This example is query_yn. | silicone/maptask |
2contradiction
| oh , come on ! an excuse like that is tantamount to lying . you ’ re essentially blaming the tech team for your time management issues , rather than accepting responsibility for the fact that you were procrastinating for the past two weeks . | This example is happiness. | silicone/dyda_e |
0entailment
| oh , come on ! an excuse like that is tantamount to lying . you ’ re essentially blaming the tech team for your time management issues , rather than accepting responsibility for the fact that you were procrastinating for the past two weeks . | This example is inform. | silicone/dyda_da |
0entailment
| Are you cold? Do you want my jacket? We should have brought the blanket, our blanket. | This example is neu. | silicone/iemocap |
0entailment
| 329 U.S. 296
67 S.Ct. 271
91 L.Ed. 296
ROTHENSIES, Collector of Internal Revenue,v.ELECTRIC STORAGE BATTERY CO.
No. 48.
Argued Nov. 15—18, 1946.
Decided Dec. 16, 1946.
Mr.Arnold Raum, of Washington, D.C., for petitioner.
Mr. Laurence H. Eldredge, of Philadelphia, Pa., for respondent.
Mr. Justice JACKSON, delivered the opinion of the Court.
1
This case represents an effort, thus far successful, to obtain advantage by way of recoupment of a claim for tax refund long since barred by the statute of limitations. The facts of this singular situation are not in dispute. From April 1919 to April 1926 the Electric Storage Battery Company paid excise taxes on the sale of storage batteries in the belief, shared by the Government, that such sales were subject to tax. In July of 1926 the company asserted otherwise and filed a refund claim. It asked refund only of the part of the taxes which it had paid between 1922 and 1926. Refund of the taxes paid earlier which the company now seeks to recoup were then barred by the statute of limitations and no claim ever has been filed for their refund and no action ever was begun for their recovery. Suit was brought, however, against the Collector for refund of the taxes paid after July 1922; judgment therefor was obtained in the district court, Electric Storage Battery Co. v. McCaughn, 52 F.2d 205; 54 F.2d 814, and affirmed by the Circuit Court of Appeals, 3 Cir., 63 F.2d 715. The Government finally settled by refund of $1,395,515.35, of which $825,151.52 represented tax and the balance interest.
2
During the years that the refunded excise tax was being collected, the taxpayer deducted it from income before calculation of its income tax, thereby deriving substantial benefits. The Commissioner, therefore, treated the refund as income for 1935, the year in which it was received, and because of it assessed additional income and excess profits taxes which with interest thereon totaled 229,805.34. The taxpayer paid the deficiency, filed claim for refund, and after it was rejected sued the Collector. It contended that the refund from the Government was not income to the taxpayer but that if it were so considered taxpayer should be permitted, as against the additional tax caused by its inclusion, to recoup the amount of the barred excise taxes which it had paid between 1919 and 1922. Both courts below correctly held that the refund was properly assessed as income. D.C., 57 F.Supp. 731; 3 Cir., 152 F.2d 521. Cf. Security Flour Mills Co. v. Commissioner, 321 U.S. 281, 64 S.Ct. 596, 88 L.Ed. 725; Freihofer Baking Co. v. Commissioner, 3 Cir., 151 F.2d 383. Both have held, however, that the income tax liability for 1935 should be extinguished by rec upment of the 1919 to 1922 excise taxes. The gravity of this holding to the administration of the tax laws led us to grant certiorari. Rothensies v. Electric Storage Battery Co., 327 U.S. 774, 66 S.Ct. 825.
3
It is not contended that there is any statutory warrant for allowing barred tax refund claims by way of recoupment or otherwise.1 Authority for it is said to be found in case law and taxpayer relies chiefly on two decisions of this Court, Bull v. United States, 295 U.S. 247, 55 S.Ct. 695, 79 L.Ed. 1421, and Stone v. White, 301 U.S. 532, 57 S.Ct. 851, 81 L.Ed. 1265. The essence of the doctrine of recoupment is stated in the Bull case; 'Recoupment is in the nature of a defense arising out of some feature of the transaction upon which the plaintiff's action is grounded.' 295 U.S. 247, 262, 55 S.Ct. 700, 79 L.Ed. 1421. It has never been thought to allow one transaction to be offset against another, but only to permit a transaction which is made subject of suit by a plaintiff to be examined in all its aspects, and judgment to be rendered that does justice in view of the one transaction as a whole.
4
The application in this general principle to concrete cases in both of the cited decisions is instructive as to the limited scope given to recoupment in tax litigation. In both cases a single transaction constituted the taxable event claimed upon and the one considered in recoupment. In both, the single transaction or taxable event had been subjected to two taxes on inconsistent legal theories, and what was mistakenly paid was recouped against what was correctly due. In Bull v. United States, the one taxable event was receipt by executors of a sum of money. An effort was made to tax it twice once under the Income Tax Act as income to the estate after decedent's death and once under the Estate Tax Act as part of decedent's gross estate. This Court held that the amount of the tax collected on a wrong theory should be allowed in recoupment against an assessment under the correct theory.2 In Stone v. White, likewise, both the claim and recoupment involved a single taxable event, which was receipt by an estate of income for a period. The trustees had paid the income tax on it but this Court held it was taxable to the beneficiary. Assessment against the beneficiary had meanwhile become barred. Then the trustees sued for a refund, which would inure to the beneficiary. The Court treated the transaction as a whole and allowed recoupment of the tax which the beneficiary should have paid against the tax the Government should not have collected from the trustees. Whatever may have been said indicating a broader scope to the doctrine of recoupment, these facts are the only ones in which it has been applied by this Court in tax cases.
5
The Government has argued that allowance of the claim of recoupment involved here would expand the holding in the Bull case. The Circuit Court of Appeals agreed that in the Bull case 'The main claim and recoupment claim were more closely connected than they are here.' Electric Storage Batt ry Co. v. Rothensies, 3 Cir., 152 F.2d 521, 524. But the court nevertheless allowed the claim because it considered that this Court had introduced the doctrine of recoupment into tax law and that it was 'based on concepts of fairness.' 152 F.2d 521, 524. It said it saw no reason for narrowly construing the requirement that both claims originate in the same transaction. We think this misapprehends the limitations on the doctrine of recoupment as applied to tax law and it leads us to state more fully reasons for declining to expand the doctrine beyond the facts of the cited cases.
6
It probably would be all but intolerable, at least Congress has regarded it as ill-advised, to have an income tax system under which there never would come a day of final settlement and which required both the taxpayer and the Government to stand ready forever and a day to produce vouchers, prove events, establish values and recall details of all that goes into an income tax contest. Hence a statute of limitation is an almost indispensable element of fairness as well as of practical administration of an income tax policy.
7
We have had recent occasion to point out the reason and the character of such limitation statutes. 'Statutes of limitation, like the equitable doctrine of laches, in their conclusive effects are designed to promote justice by preventing surprises through the revival of claims that have been allowed to slumber until evidence has been lost, memories have faded, and witnesses have disappeared. The theory is that even if one has a just claim it is unjust not to put the adversary on notice to defend within the period of limitation and that the right to be free of stale claims in time comes to prevail over the right to prosecute them.' Order of Railroad Telegraphers v. Railway Express Agency, 321 U.S. 342, 348, 349, 64 S.Ct. 582, 586, 88 L.Ed. 788. 'They are by definition arbitrary, and their operation does not discriminate between the just and the unjust claim, or the voidable (avoidable) and unavoidable delay. They have come into the law not through the judicial process but through legislation.' Chase Securities Corp. v. Donaldson, 325 U.S. 304, 314, 65 S.Ct. 1137, 1142, 89 L.Ed. 1628.
8
As statutes of limitation are applied in the field of taxation, the taxpayer sometimes gets advantages and at other times the Government gets them. Both hardships to the taxpayers and losses to the revenues may be pointed out.3 They tempt the equity-minded judge to seek for ways of relief if individual cases.
9
But if we should approve a doctrine of recoupment of the breadth here applied we would seriously undermine the statute of limitations in tax matters. In many, if not most, cases of asserted deficiency the items which occasion it relate to past years closed by statute, at least as closely as does the item involved here. Cf. Hall v. United States, 95 Ct.Cl. 539, 43 F.Supp. 130. The same is true of items which form the basis of refund claims. Every assessment of deficiency and each claim for refund would invite a search of the taxpayer's entire tax history for items to recoup. This cas provides evidence of the extent to which this would go. When this suit was brought in 1943, the claim pleaded as a recoupment was for taxes collected over twenty years before and for over sixteen years barred by the statute. That claims dead so long can be resurrected under this doctrine, is enough to show its menace to the statute of limitations—at least as to those taxpayers whose affairs by accident or design take such shape that they can avail themselves of recoupment remedies. Moreover, we have held that the Tax Court has no jurisdiction to consider recoupment. Gooch Milling and Elevator Co. v. Commissioner, 320 U.S. 418, 64 S.Ct. 184, 88 L.Ed. 139. Hence, the availability of the remedy would depend on diverting the litigation to the district courts.
10
We cannot approve such encroachments on the policy of the statute out of consideration for a taxpayer who for many years failed to file or prosecute its refund claim. If there are to be exceptions to the statute of limitations, it is for Congress rather than for the Courts to create and limit them.
11
The judgment below is reversed.
12
Reversed.
13
Mr. Justice MURPHY is of the opinion, in which Mr. Justice BLACK and Mr. Justice RUTLEDGE join, that the judgment below should be affirmed. He believes that the claims for refund of the illegal assessments exacted from 1919 to 1922 arise out of the same subject matter as was involved in the Government's demand for additional taxes for 1935, thereby making applicable the rule of Bull v. United States, 295 U.S. 247, 55 S.Ct. 695, 79 L.Ed. 1421.
1
Indeed, the applicable provisions of the Revenue Act of 1928 seem to direct a result opposite to that asked by respondent. Section 608 provides that 'A refund of any portion of an internal-revenue tax (or any interest, penalty, additional amount, or addition to such tax) made after the enactment of this Act, shall be considered erroneous—(a) if made after the expiration of the period of limitation for filing claim therefor, unless within such period claim was filed; * * *.' 26 U.S.C.A. Int.Rev.Acts, page 459. Section 609(b) provides, 'A credit of an overpayment in respect of any tax shall be void if a refund of such overpayment would be considered erroneous under section 608.' 45 Stat. 874, 875, 26 U.S.C.A. Int.Rev.Acts, page 460. And cf. McEachern v. Rose, 302 U.S. 56, 58 S.Ct. 84, 82 L.Ed. 46.
2
But the Court emphasized that refund of the incorrect tax was not barred by the statute at the time the Government proceeded for collection of the correct tax.
3
In American Light & Traction Co. v. Harrison, 7 Cir., 142 F.2d 639, 154 A.L.R. 1042, the court did not allow recoupment to the Government. But judiciously, it said, 'Although here a hardship on the Government results from the taxpayer's inconsistency, the correlative provisions of this same statute will, in the converse of the instant situation, work an equal hardship on the taxpayer.' 142 F.2d 639, 643. Whether or not the statute, §§ 608 and 609 of the Revenue Act of 1928, be taken to compel the conclusion we reach in this case, the court's recognition that both parties to taxation are affected impartially, though perhaps harshly, by policy of repose has application here. It may easily be overlooked, when the unfairness of the Government's retaining incorrectly collected monies of respondent is stressed, that the statute of limitations is primarily an instrument of fairness.
| This example is 12. | lex_glue/scotus |
2contradiction
| Any notice required or permitted to be delivered hereunder shall be deemed to be delivered when sent by facsimile with receipt confirmed or when deposited in the United States mail, postage prepaid, registered or certified mail, return receipt requested, or by overnight courier, addressed to the parties at the address first stated herein, or to such other address as either party hereto shall from time to time designate to the other party by notice in writing as provided herein. | This example is Binding Effects. | lex_glue/ledgar |
0entailment
| میں نے ایک دن میں دیکھا تھا اور آپ کو معلوم ہے کہ وہ لوئیزویل میں موجود تھے اور اس کے علاوہ اور یہ کہ ان کی مرمت کی گئی ہے | This example is ur. | language-identification |
0entailment
| I guess this is meant to be a sort of reworking or updating of "Beauty and the Beast", but I can't say I've ever watched a movie that began with several minutes of graphic horse sex. Wow. Anyway it seems that a young woman and her..aunt? Have traveled to this castle in France where the woman is to be married to the son of the castle owner, who is the man who takes care of making sure the horses get their rocks off. It seems that there are legends in that area of a beast that was rather, uh, frisky, I guess you could say, with the ladies, or at least, one in particular. There are all kinds of references tucked away in that regard but every time the soon-to-be-blushing young bride gets her curious little hands on one the groom's father removes it from her sight. Anyway, the young bride-to-be goes upstairs to sleep while the family is waiting for a Cardinal to show up to the wedding (a family member, I guess) and as she dreams she dreams of a beast in the woods that has its way with her. The effects in this leave a little to be desired, and any attempt at eroticism (not that I know much about that) is kind of rendered laughable, especially when certain featured appendages appear about as realistic as a bed post or a baseball bat. This has a rather strange and abrupt, yet twist ending, with not really any clues or much build up to it, but it was kind of fitting and definitely not what I expected. I don't know, this is kind of a tough one to get through but it has its moments and is definitely weird. 7 out of 10. | This example is pos. | imdb |
0entailment
| illuminating if overly talky documentary . | This example is pos. | rotten_tomatoes |
0entailment
| Powell's China Comments Anger Taiwanese (AP) AP - Secretary of State Colin Powell has angered Taiwanese officials and lawmakers by making unusually strong comments denying that the island is an independent nation and suggesting Taiwan should unify with China. | This example is World. | ag_news |
2contradiction
| I went on a Saturday and had very friendly service. The first guy had a thick accent, so it was hard to understand him, but there was another lady who recommended I just have oysters with lemon. I ordered a dozen Beausoleil oysters for only 18$ (happy hour special) and it was yummy! \n\nI asked the same waiter what he suggested for wine--Prosecco, sparkling wine that cost $13 a glass! It was expensive, but very delicious and went well with the oysters.\n\nI also ordered the $16 1.5 lbs of mussels. I think that's really good price as it filled me up. The waiter recommended a flavor (it had tomatoes, celery and carrots) and he has good taste! I gobbled them up and had a great time. Mmm, seafood.\n\nThey had awesome service, and I felt like the food was delicious. It's a bit pricey, but they were friendly.\n\nDefinitely recommend the mussels - I feel like that was a great deal and I was super stuffed. They have an all you can eat mussels day - if you have time and a stomach to eat more than 1.5 lbs, I definitely recommend going.\n\nEdit: Prosecco isn't $18, sorry for the mixup | This example is 1 star. | yelp_review_full/yelp_review_full |
2contradiction
| No planned closing date was provided . | This example is negative. | financial_phrasebank/sentences_allagree |
0entailment
| that has a charmingly bourbon air. | This example is positive. | poem_sentiment |
0entailment
| Jean-François-Joseph Duval (July 17 1802 – May 6 1881) was a lawyer judge and political figure in Quebec. He represented Quebec Upper Town in the Legislative Assembly of Lower Canada from 1829 to 1834.He was born in Quebec City the son of François Duval and Ann Eliza Germain. Duval was educated at the Petit Séminaire de Québec studied law with George Vanfelson and then Joseph-Rémi Vallières de Saint-Réal and was admitted to the bar in 1823 entering practice with Vallières de Saint-Réal. | This example is OfficeHolder. | dbpedia_14/dbpedia_14 |
2contradiction
| This is the third Nancy Drew cd game I have purchased. I have bought them in reverse order, though, with Message in a Haunted Mansion being first, then Stay Tuned for Danger, then this one. I highly recommend all of them. They are all a lot of fun, challenging and humorous in places. My only complaint on this one (which wouldn't change my opinion on how much fun it is to play) is that this is the only one out of all three that uses cartoon drawings for the characters, instead of 3D graphic animation, like the other two. The scenery is all 3D,though, just like the rest. Needless to say they improved upon this minor detail in the other two games. They are definitely must-buys! | This example is negative. | amazon_polarity/amazon_polarity |
0entailment
| Strange how the Swedes were once the most peaceful people in the world , then the Jews make them into liberals who wanted to genocide them selves . | This example is hate. | hate_speech18 |
0entailment
| Watching telugu movie..wat abt u?
| This example is ham. | sms_spam |
0entailment
| #WomensMarch against <Donald Trump/> around the world : kitchens :
#WomensMarch against <Donald Trump/> around the world : men : | This example is sentence1. | humicroedit/subtask-2 |
2contradiction
| Tell Valery how long it's gonna take to join her | This example is GetWeather. | snips_built_in_intents |
2contradiction
| RT @BlazeTheGreat_: I hate when niggas get mad cuz you fucked they girl when really he should be happy you showed him that bitch unloyal | This example is hate speech. | hate_speech_offensive |
0entailment
| i have big bf problems?
ok so i am agery at my bf and its his bday in two days. i went away over the weekend. i sent him an email before i left. i checked my email today he sent nothing. he didn't come online even though he knew i would be home today. he didn't even send an email says why he wasn't going to be on. this is not like him at all. he normal sends me tons of emails saying how he missed me and love me. i am 15 by the way. he is 16 turning 17. i am agery at him cause he is seppose to show how he cares right. should i yell at him when i see him tommorw or just let it go. i mean i should ask atleast right. i am so new to this reltionship stuff cause this is my frist. i have only been with him two months and he is real improtant to me. | This example is Family & Relationships. | yahoo_answers_topics |
2contradiction
| Mr. Trump says Mrs. Clinton wants “amnesty for everybody, come on in, come on over.” Mrs. Clinton said that she had helped eight million children obtain health coverage, Sept. 11 responders receive medical care and children get safer medicines. Mr. Trump said Mrs. Clinton ignored 600 requests for increased security from J. Christopher Stevens, the ambassador to Libya, and communicated only with Sidney Blumenthal. Mr. Trump accused Mrs. Clinton of being there for President Obama’s “line in the sand” in Syria. She said she wasn’t. Mr. Trump, referring to the effect of Nafta and other free-trade agreements, said, “We lost our jobs.” Mr. Trump said that the United States signed a “peace treaty” to bring an end to the civil war in Syria. Mr. Trump admitted that he used a $916 million loss declared on his 1995 tax returns to avoid paying federal income taxes. But he refused to say how many years he paid no income tax and simultaneously claimed to have paid a “tremendous” amount of taxes. Mr. Trump said we have hundreds of thousands of people pouring into the United States from places like Syria, and we have no idea who they are. Mr. Trump said that growth is “down to 1 percent” and that taxes in the United States are the “highest in the world.” “Since the Great Recession the gains have all gone to the top.” Mr. Trump said “maybe there is no hacking,” in response to Mrs. Clinton’s claim that Russians are engaged in an unprecedented effort to influence the election — on Mr. Trump’s behalf. Mr. Trump said that Mrs. Clinton “wants to go to a single-payer plan” like the health care system in Canada. Mr. Trump said “many people saw” bombs all over the apartment of a couple who committed the terrorist attack in San Bernardino, Calif. Mrs. Clinton deleted 33,000 emails from her private server even after she got a subpoena from Congress. Mr. Trump said that a Clinton associate pushed the “birther” notion against Obama in 2008. Mrs. Clinton said there was no evidence her email has been hacked by a foreign power. Former President Bill Clinton was impeached, lost his law license and paid an $850,000 fine to Paula Jones. Mr. Trump accused Mrs. Clinton of laughing about getting a man acquitted of raping a 12-year-old girl. When Mr. Trump was asked whether he has kissed women or groped women without consent, as he claimed on a recently released video, Mr. Trump said no, he had not. Mr. Trump said that Obamacare is leading to insurance rate increases that are “astronomical.” Mr. Trump said that last year, the United States had a trade deficit of $800 billion. | This example is true. | hyperpartisan_news |
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