Commissioner of Internal Revenue v. Lundy

Summary

The Supreme Court held that when a taxpayer has not filed a return before the IRS mails a notice of deficiency, the two‑year look‑back period in 26 U.S.C. § 6512(b)(3)(B) applies, so the Tax Court lacked jurisdiction to award a refund of taxes paid earlier; the Court reversed the Fourth Circuit and the Tax Court judgment. Justice Thomas and Justice Stevens each dissented, arguing that Lundy should be allowed a three‑year look‑back and a refund.