United States v. Brockamp,
Annotate this Case
519 U.S. 347 (1997)
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OCTOBER TERM, 1996
UNITED STATES v. BROCKAMP, ADMINISTRATOR OF THE ESTATE OF McGILL, DECEASED
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
No. 95-1225. Argued December 3, 1996-Decided February 18, 1997*
After the taxpayer in each of these cases paid the Internal Revenue Service (IRS) money he did not owe, he (or his representative) submitted an administrative refund claim several years past the end of the applicable filing period set forth in § 6511 of the Internal Revenue Code of 1986. Each taxpayer asked the court to extend the statutory period for an "equitable" reason, namely, that he had a mental disability (senility or alcoholism) that caused the delay. Such a reason is not mentioned in § 6511, but, in both cases, the Ninth Circuit read the statute as if it contained an implied "equitable tolling" exception. It then applied equity principles to each case, found that those principles justified tolling the statutory period, and permitted the actions to proceed.
Held: Congress did not intend the "equitable tolling" doctrine to apply to § 6511's time (and related amount) limitations for filing tax refund claims. The taxpayers misplace their reliance on Irwin v. Department of Veterans Affairs, 498 U. S. 89, 94-96. Even assuming, as they contend, that a tax refund suit and a private restitution suit are sufficiently similar to warrant asking Irwin's negatively phrased question-Is there good reason to believe that Congress did not want the equitable tolling doctrine to apply in a suit against the Government?-there are strong reasons for answering that question in the Government's favor. Section 6511 sets forth its time limitations in a highly detailed technical manner, reiterates them several times in different ways, imposes substantive limitations, and sets forth explicit exceptions to its basic time limits that do not include "equitable tolling." To read such tolling into these provisions would require one to assume an implied tolling exception virtually every time a number appears in § 6511, and would require the tolling of that section's substantive limitations on the amount of recovery-a kind of tolling for which there is no direct precedent. There are no counterindications of congressional intent. Reading "equitable tolling" into the statute could create serious administrative problems by forcing the IRS to respond to, and perhaps litigate, large
*Together with United States v. Scott, also on certiorari to the same court (see this Court's Rule 12.4).
numbers of late claims. That fact suggests that, at the least, Congress would likely have wanted to decide explicitly whether, or just where and when, to expand the statute's limitations periods, rather than delegate to the courts a generalized power to do so wherever it appears that equity so requires. The taxpayers' counterrebuttal, consisting primarily of a historical analysis of the tax refund provisions, actually helps the Government's argument. pp. 349-354.
BREYER, J., delivered the opinion for a unanimous Court.
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.
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