Case: ‘Discovery Rule’ Does Not Apply to Late-Filed Tax Refund Claims (Fed. Cl.) (IRC §6511)

No equitable ability to extend a statute of limitation period for filing a refund claim even when a taxpayer discovers an overpayment of FICA taxes after the statutory deadline, the Court of Federal Claims held, in rejecting what it terms a “discovery rule. Taxpayer sought a tax refund claiming he overpaid his FICA taxes as a “result of United Airlines canceling [his] pension plan.” It was undisputed that Taxpayer’s refund claim was not filed, as required in tax code Section 6511, within three years of the filing of the relevant return, nor within two years of the payment ...