United States v. Brockamp (1996)
- Docket
- 95-1225
- Decided
- 1996-01-01
Summary
Question: May courts toll, for nonstatutory reasons, the statutory time limitations for filing tax refund claims set forth in the Internal Revenue Code of 1986? Conclusion: No. In a unanimous decision authored by Justice Stephen G. Breyer, the Court ruled that Congress did not intend the "equitable tolling" doctrine to apply to the Internal Revenue Code of 1986's time limitations for filing tax refund claims. Justice Breyer wrote that allowing such exceptions to the filing deadline "could create serious administrative problems by forcing the IRS to respond to, and perhaps litigate, large numbers of late claims."