ME Med. Ctr. v. United States, No. 11-1426 (1st Cir. 2012)Annotate this Case
In August 2004, MMC began to look into filing a tax refund claim for reimbursement of FICA made on behalf of its medical residents in 2001. In March 2005, MMC discussed the matter with its accountants. On April 15, 2005, the day the claim was due, MMC completed the form; it has no evidence that it followed its standard practice and took the form to the post office. The IRS asserts that it has no record of receiving the claim. In December 2009, MMC filed a refund suit. The government refused to respond to discovery requests relating to the 2001 claim, arguing that the claim was not timely filed. The district court entered judgment for the government. The First Circuit affirmed, holding that MMC did not make an adequate threshold showing that its refund claim was timely filed, and thus the district court did not have jurisdiction to hear the case.
The court issued a subsequent related opinion or order on April 11, 2012.