Cite as: 519 U. S. 347 (1997)
Opinion of the Court
decided to pay the price of occasional unfairness in individual cases (penalizing a taxpayer whose claim is unavoidably delayed) in order to maintain a more workable tax enforcement system. At the least it tells us that 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 a court concludes that equity so requires.
The taxpayers' counterrebuttal consists primarily of an interesting historical analysis of the Internal Revenue Code's tax refund provisions. They try to show that § 6511's specific, detailed language reflects congressional concern about matters not related to equitable tolling. They explain some language, for example, in terms of a congressional effort to stop taxpayers from keeping the refund period open indefinitely through the device of making a series of small tax payments. See S. Rep. No. 398, 68th Cong., 1st Sess., 33 (1924). They explain other language as an effort to make the refund time period and the tax assessment period coextensive. See H. R. Rep. No. 2333, 77th Cong., 2d Sess., 52 (1942). Assuming all that is so, however, such congressional efforts still seem but a smaller part of a larger congressional objective: providing the Government with strong statutory "protection against stale demands." Cf. United States v. Garbutt Oil Co., 302 U. S. 528, 533 (1938) (statute of limitations bars untimely amendment of claim for additional re-fund). Moreover, the history to which the taxpayers point reveals that § 6511's predecessor tax refund provisions, like § 6511, contained highly detailed language with clear time limits. See, e. g., § 281(b) of the Revenue Act of 1924, ch. 234, 43 Stat. 301 (4-year limit on claims for overpayment of income, war-profits, or excess-profits tax and cap on refund amount); § 322(b) of the Revenue Act of 1932, ch. 209, 47 Stat. 242 (2-year limit for claim filing and corresponding limit on refund amount); Internal Revenue Code of 1954, 68A Stat. 808 (adopting current alternative time and amount limita-
353
Page: Index Previous 1 2 3 4 5 6 7 8 NextLast modified: October 4, 2007