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BARAL v. UNITED STATES

No. 98-1667.

528 U.S. 431 (2000)

BARAL v. UNITED STATES

United States Supreme Court.

Decided February 22, 2000.

Attorney(s) appearing for the Case

Walter J. Rockler argued the cause for petitioner. With him on the briefs were Julius Greisman and Thomas Klein.

Kent L. Jones argued the cause for the United States. With him on the brief were Solicitor General Waxman, Assistant Attorney General Argrett, Deputy Solicitor General Wallace, Gilbert S. Rothenberg, and Charles Bricken.

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

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. §...

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