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UNITED STATES v. BROCKAMP

No. 95-1225.

519 U.S. 347 (1997)

UNITED STATES v. BROCKAMP, administrator of THE ESTATE OF McGILL, DECEASED.

United States Supreme Court.

Decided February 18, 1997.

Attorney(s) appearing for the Case

Deputy Solicitor General Wallace argued the cause for the United States. With him on the briefs were Acting Solicitor General Dellinger, Assistant Attorney General Argrett, Kent L. Jones, Gilbert S. Rothenberg, and Bridget M. Rowan.

Robert F. Klueger argued the cause and filed a brief for respondents.

Breyer, J., delivered the opinion for a unanimous Court.

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...

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