Supreme Court of the United States
United States v. Clintwood Elkhorn Mining Co.
April 15, 2008553 U.S. 1
Summary
The Court held that taxpayers seeking refunds of taxes collected in violation of the Export Clause must comply with the Internal Revenue Code's administrative refund procedures and filing deadlines before suing the Government. The Tucker Act's longer limitations period cannot circumvent those requirements, and the constitutional basis of the refund claim does not create an exception. The Court reversed the Court of Appeals without reaching the separate interest issue.
Holding
- Applicability of the Internal Revenue Code refund scheme to Export Clause claims. A taxpayer seeking a refund of a tax assessed in violation of the Export Clause must file a timely administrative refund claim before bringing suit against the Government. The Tucker Act's six-year limitations period does not displace the Code's specific refund procedures and deadlines.
- Exception for facially unconstitutional taxes. The refund scheme applies even when the taxpayer characterizes the tax as facially unconstitutional or as an exaction outside the genuine scope of the taxing power. The statutory language independently covers any sum alleged to have been wrongfully collected.
Docket 07-308
Cited authorities
- IRS Notice 2000-28
- 26 U.S.C. § 4121
- 26 U.S.C. § 7422
- 26 U.S.C. § 6511
- 26 U.S.C. §4121
- 26 U.S.C. § 7421
- 26 U.S.C. § 7421
- 26 U.S.C. §§ 7422