Robert E. Wadlow and Connie V. Wadlow - Page 39

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               Section 6511's detail, its technical language, the                     
               iteration of the limitations in both procedural and                    
               substantive forms, and the explicit listing of                         
               exceptions, taken together, indicate to us that                        
               Congress did not intend courts to read other                           
               unmentioned, open-ended, "equitable" exceptions into                   
               the statute that it wrote. * * * [United States v.                     
               Brockamp, 519 U.S. 347, 352 (1997).]                                   
               We should follow the admonitions of the Supreme Court and              
          apply sections 6512(b), 6511(c), 6501(c)(4), and 183(e)(4) in               
          accordance with their literal terms and hold that we lack                   
          jurisdiction to determine any overpayments in this case.                    
               JACOBS, GERBER, WELLS, WHALEN, COLVIN, HALPERN, THORNTON,              
          and MARVEL, JJ., agree with this dissent.                                   

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