Case: Three-and-a-Half-Year Look-Back Period Bars Refund Claim Despite Timely Filing of Formal Claim (9th Cir.) (IRC §6511)

Taxpayers could not recover a tax overpayment of almost $700,000 because they missed the three-and-a-half-year look-back period under I.R.C. §6511(b)(2)(A) by a mere three months, even though they timely filed a formal refund claim under §6511(a), the U.S. Court of Appeals for the Ninth Circuit held, affirming the district court’s dismissal. Taxpayers, a married couple, had a practice of overpaying their federal income taxes and applying the overpayment credits to the following year’s tax liability. Due to their accountant’s negligence, Taxpayers did not file their 2011 tax return until January 2016, seeking a refund of $692,690 in overpayments from previous ...