United States v. Marian Brockamp, Administrator of the Estate of Stanley B. Mcgill, Deceased (519 U.S. 347)
U.S. Supreme Court · decided February 18, 1997 · Supreme Court Database (Spaeth)
- Citation
- 519 U.S. 347 · 117 S. Ct. 849
- Decided
- February 18, 1997
- Term
- October Term 1996
- Vote
- 9–0
- Majority author
- Justice Breyer
- Issue area
- Federal Taxation
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Breyer delivered the opinion of the Court. The two cases before us raise a single question. Can courts toll, for nonstatutory equitable reasons, the statutory time (and related amount) limitations for filing tax refund claims set forth in §6511 of the Internal Revenue Code of 1986? We hold that they cannot. These two cases present similar circumstances. In each case a taxpayer initially paid the Internal Revenue Service (IRS) several thousand dollars that he did not owe. In each case the taxpayer (or his representative) filed an administrative claim for refund several years after the relevant statutory time period for doing so had ended. In each case the taxpayer suffered a disability (senility or alcoholism), which, he said, explained why the delay was not his fault. And in each case he asked the court to extend the relevant statutory time period for an “equitable” reason, namely, the existence of a mental disability — a reason not mentioned in §6511, but which, we assume, would permit a court to toll the statutory limitations period if but only if, §6511 contains an implied “equitable tolling” exception. See 4 C. Wright & A. Miller, Federal Practice and Procedure § 1056 (2d ed. 1987 and Supp. 1996); see also Wolin v. Smith Barney, Inc., 88 F. 3d 847, 852 (CA7 1996) (defining equitable tolling). In both cases, the Ninth Circuit read §6511 as if it did contain an…
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