348
Opinion of the Court
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
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