UNITED STATES v. BROCKAMP

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Case Basics
Docket No. 
95-1225
Petitioner 
United States
Respondent 
Brockamp
Consolidation 
No. ?
Advocates
(Argued the cause for the respondent)
(Department of Justice, argued the cause for the petitioner)
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Facts of the Case 

Stanley B. McGill, whose estate is administrated by Marion Brockamp, paid the Internal Revenue Service money he did not owe. McGill, or his representative, submitted an administrative refund claim several years past the end of the applicable filing period set forth in the Internal Revenue Code of 1986. McGill asked the court to extend the statutory period for an "equitable" reason, namely that he had a mental disability that caused the delay. Although such a reason is not mentioned in the Internal Revenue Code, the Court of Appeals read the statute as if it contained an implied "equitable tolling" exception, which the court found justified, and therefore permitted the actions to proceed.

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 
Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Internal Revenue Code

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."

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UNITED STATES v. BROCKAMP. The Oyez Project at IIT Chicago-Kent College of Law. 21 October 2014. <http://www.oyez.org/cases/1990-1999/1996/1996_95_1225>.
UNITED STATES v. BROCKAMP, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1990-1999/1996/1996_95_1225 (last visited October 21, 2014).
"UNITED STATES v. BROCKAMP," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 21, 2014, http://www.oyez.org/cases/1990-1999/1996/1996_95_1225.