United States v. Williams, 514 U.S. 527, 8 (1995)

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534

UNITED STATES v. WILLIAMS

Opinion of the Court

a "taxpayer," the Government relies on 26 U. S. C. 7701 (a)(14), which defines "taxpayer" as "any person subject to any internal revenue tax." According to the Government, a party who pays a tax is not "subject to" it unless she is the one assessed.

The Government's argument fails at both statutory junctures. First, the word "taxpayer" in 6511(a)—the provision governing administrative claims—cannot bear the weight the Government puts on it. This provision's plain terms provide only a deadline for filing for administrative relief,7 not a limit on who may file. To read the term "taxpayer" as implicitly limiting administrative relief to the party assessed is inconsistent with other provisions of the refund scheme, which expressly contemplate refunds to parties other than the one assessed. Thus, in authorizing the Secretary to award a credit or refund "[i]n the case of any overpayment," 26 U. S. C. 6402(a) describes the recipient not as the "taxpayer," but as "the person who made the overpayment." Similarly, in providing for credits and re-funds for sales taxes and taxes on tobacco and alcohol, 26 U. S. C. 6416(a) and 26 U. S. C. 6419(a) describe the recipient as "the person who paid the tax."

tion of 6 months from the date of filing the claim required under such section unless the Secretary renders a decision thereon within that time, nor after the expiration of 2 years from the date of mailing by certified mail or registered mail by the Secretary to the taxpayer of a notice of the disallowance of the part of the claim to which the suit or proceeding relates."

7 As a statute of limitations, 6511(a) does narrow the waiver of sovereign immunity in 1346(a)(1) by barring the tardy. See United States v. Dalm, 494 U. S. 596, 602 (1990) ("Read together, the import of these sections [ 1346(a)(1), 7422(a), 6511(a)] is clear: unless a claim for refund of a tax has been filed within the time limits imposed by 6511(a), a suit for refund, regardless of whether the tax is alleged to have been 'erroneously,' 'illegally,' or 'wrongfully collected,' 1346(a)(1), 7422(a), may not be maintained in any court.").

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