United States Federal Circuit

In an action seeking refund of the Federal Communications Excise Tax, the Court of Federal Claims judgment is affirmed where the court properly dismissed the 1996 claim for lack of jurisdiction under RCFC 12(b)(1), as plaintiff's 1996 claim was not timely filed with the IRS pursuant to 26 U.S.C. sec. 6511(a) and thus plaintiff was barred from bringing suit pursuant to 26 U.S.C. sec. 7422.

Appellate Information

• Decided 05/26/2009
• Published 05/26/2009

Judges

Court

• United States Federal Circuit

Counsel