432
Opinion of the Court
the income tax), that are converted into income tax only on the income tax return. Rather, they are methods for collecting income taxes. And the Tax Code directly contradicts Baral's notion that income tax is "paid" under § 6511(b)(2)(A) only when the income tax is assessed. See § 6151(a). His position also finds no support in Rosenman v. United States, 323 U. S. 658, and would work to the detriment of timely taxpayers, who would be denied interest for the time between filing a return claiming a refund or credit and the Service's assessment. Pp. 434-439. 172 F. 3d 918, affirmed.
Thomas, J., delivered the opinion for a unanimous Court.
Walter J. Rockler argued the cause for petitioner. With him on the briefs were Julius Greisman and Thomas Klein.
Kent L. Jones argued the cause for the United States. With him on the brief were Solicitor General Waxman, Assistant Attorney General Argrett, Deputy Solicitor General Wallace, Gilbert S. Rothenberg, and Charles Bricken.
Justice Thomas delivered the opinion of the Court. Internal Revenue Code § 6511(b)(2)(A) imposes a ceiling on the amount of credit or refund to which a taxpayer is entitled as compensation for an overpayment of tax: "[T]he amount of the credit or refund shall not exceed the portion of the tax paid within the period, immediately preceding the filing of the claim, equal to 3 years plus the period of any extension of time for filing the return." 26 U. S. C. § 6511(b)(2)(A). We are called upon in this case to decide when two types of remittance are "paid" for purposes of this section: a remittance by a taxpayer of estimated income tax, and a remittance by a taxpayer's employer of withholding tax. The plain language of a nearby Code section, § 6513(b), provides the answer: These remittances are "paid" on the due date of the taxpayer's income tax return.
I
The relevant facts are not disputed. Two remittances were made to the Internal Revenue Service toward peti-
Page: Index Previous 1 2 3 4 5 6 7 8 9 NextLast modified: October 4, 2007