354
Opinion of the Court
tions); see also § 810 of the Revenue Act of 1932, ch. 209, 47 Stat. 283 (imposing time and amount limits for estate tax refunds). And that history lacks any instance (but for the present cases) of equitable tolling. On balance, these historical considerations help the Government's argument.
For these reasons, we conclude that Congress did not intend the "equitable tolling" doctrine to apply to § 6511's time limitations. The Ninth Circuit's decisions are
Reversed.
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