David H. Baral v. United States (528 U.S. 431)
U.S. Supreme Court · decided February 22, 2000 · Supreme Court Database (Spaeth)
- Citation
- 528 U.S. 431 · 120 S. Ct. 1006
- Decided
- February 22, 2000
- Term
- October Term 1999
- Vote
- 9–0
- Majority author
- Justice Thomas
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice Thomas delivered the opinion of the Court. Internal Revenue Code § 6511(b)(2)(A) imposes a ceiling on the amount of credit or refund to which a taxpayer is entitled as compensation for an overpayment of tax: “[T]he amount of the credit or refund shall not exceed the portion of the tax paid within the period, immediately preceding the filing of the claim, equal to 3 years plus the period of any extension of time for filing the return.” 26 U. S. C. § 6511(b)(2)(A). We are called upon in this case to decide when two types of remittance are “paid” for purposes of this section: a remittance by a taxpayer of estimated income tax, and a remittance by a taxpayer’s employer of withholding tax. The plain language of a nearby Code section, § 6513(b), provides the answer: These remittances are “paid” on the due date of the taxpayer’s income tax return. I The relevant facts are not disputed. Two remittances were made to the Internal Revenue Service toward petitioner David H. Baral’s income tax liability for the 1988 tax year. The first, a withholding of $4,104 from Baral’s wages throughout 1988, was a garden-variety collection of income tax by the employer, see §3402. The second, an estimated income tax of $1,100 remitted in January 1989, was sent by Baral himself out of concern that his employer’s withholding might be inadequate to meet his tax obligation for the year, see §6654.…
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