Justia, United States v. Brockamp, 519 U.S. 347 (1997) (Internet Archive copy of Sept. 8, 2025)

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The Justia copy of the Supreme Court syllabus and opening of United States v. Brockamp, 519 U.S. 347 (1997), No. 95-1225, argued December 3, 1996 and decided February 18, 1997, on certiorari to the United States Court of Appeals for the Ninth Circuit. In each case a taxpayer filed a refund claim years after the period set by § 6511 of the Internal Revenue Code of 1986, and asked the court to extend the period because of a mental disability. The syllabus states that Congress did not intend the "equitable tolling" doctrine to apply to the time limitations of § 6511 for filing tax refund claims, and the Ninth Circuit judgments are reversed. Justice Breyer delivered the opinion for a unanimous Court.

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United States v. Brockamp, 519 U.S. 347 (1997)

OCTOBER TERM, 1996

Syllabus

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).

348

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.

67 F.3d
260 and 70 F.3d
120 , reversed.

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

349 Full Text of Opinion

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