Baral v. United States

Summary

The Court held that, for purposes of the look‑back ceiling in §6511(b)(2)(A), both employer‑withheld tax and taxpayer‑paid estimated tax are deemed paid on the due date of the return (April 15 of the year following the taxable year) under §§6513(b)(1)‑(2), so they fall outside the three‑year‑plus‑extension look‑back period and the refund credit is zero. The Service’s denial of the credit was therefore correct.