Ralston Steel Corp. v. United States

stating that when “factual allegations [in the complaint] would arguably show an actual contract between the plaintiff (or the agents) and defendant^] the court therefore has jurisdiction to decide the issue” | finding a statute mandating the payment of money in a combination of sections 7122 and 7809 of the Internal Revenue Code | agreement to pay taxes in order to remove a threat of levy was an implied-in-fact contract | Suit seeking recovery of taxes paid to the Internal Revenue Service; a claim must be “arguable” to not be “frivolous.” | Jurisdiction is appropriate if a claim “is not frivolous but arguable.” | Jurisdiction is appropriate if a claim “is not frivolous but arguable.” | “In general, a claimant who says that he is entitled to money from the United States because a statute or a regulation grants him that right, in terms or by implication, can properly come to the Court of Claims, at least if his claim is not frivolous but arguable.” | jurisdiction is established by non-frivolous claim | “In general, a claimant who says that he is entitled to money from the United States because a statute or a regulation grants him that right, in terms or by implication, can properly come to the Court of Claims, at least if his claim is nor frivolous but arguable.”