Stauffer v. Internal Revenue Service, No. 18-2105 (1st Cir. 2019)Annotate this Case
The First Circuit affirmed the judgment of the district court dismissing the complaint filed by Hoff Stauffer on behalf of the estate of Carlton Stauffer, his father, against the Internal Revenue Services (IRS) alleging that the IRS improperly denied his April 2013 for his father's 2006 tax refund as untimely, holding that the Estate's arguments on appeal were unavailing.
Before the district court, the Estate argued that the applicable statute of limitations for the filing of a tax refund claim was tolled due to Carlton's financial disability. The district court disagreed, concluding that because Hoff held a durable power of attorney (DPA) authorizing him to act on behalf of Carlton in financial matters the limitations period was not tolled. The First Circuit affirmed, holding (1) the DPA qualified Hoff as a person authorized to act on behalf of Carlton in financial matters for the purposes of I.R.C. 6511(h)(2)(B); and (2) there was no clear error in the court's factual finding that Hoff never renounced the DPA.