United States v. Brockamp

Summary

Justice Breyer delivered the unanimous opinion holding that courts cannot equitably toll the time and related amount limitations for tax refund claims under 26 U.S.C. §6511. Even assuming that Irwin’s presumption favoring equitable tolling applied, the statute’s detailed and emphatic language, repeated procedural and substantive limitations, express exceptions, and the administrative demands of tax collection rebutted that presumption. The Court reversed the Ninth Circuit’s decisions permitting the taxpayers’ late refund claims to proceed. There were no separate opinions.