Schaeffler v. United States, No. 17-10719 (5th Cir. 2018)Annotate this Case
The Fifth Circuit affirmed the district court's grant of the Government's motion to dismiss taxpayers' action seeking a refund for an overpayment because it was time-barred. The court agreed with the district court and the government that the claim was filed after the general limitations period in I.R.C. 6511(a) and that the special limitations period in I.R.C. 6511(d)(3)(A) did not apply as the overpayment was not attributable to foreign taxes for which credit was allowed.
The court issued a subsequent related opinion or order on May 22, 2018.