Case: Refund Claim Not Properly Filed, Claim Dismissed (Fed. Cl.) (IRC §7422)

Taxpayer’s refund claim for the 2010 tax year was not duly filed because it lacked supporting documentation, the U.S. Court of Federal Claims held, granting the government’s motion to dismiss. Taxpayer, an individual, failed to file a timely return for 2010. The IRS prepared a substitute return and seized funds to satisfy the tax liability determined on the substitute return. Taxpayer filed an amended return reporting significantly lower income for 2010 than the IRS had calculated, along with a claim for refund, but did not provide any documentation to substantiate the revised figures. The court held that Taxpayer’s refund claim ...