In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have certain consequences—particularly when there are so many deadlines for tax filings, payments, even claims for refund. In a recent decision by the Eighth Circuit Court of Appeals, the Court affirmed the lower court’s determination to dismiss the taxpayer’s lawsuit against the IRS. The taxpayer, the Court held, missed the period of limitation on filing a claim for refund, and, therefore, the Court did not have subject-matter jurisdiction.
28 U.S.C. § 1346
Generally, federal district courts have original jurisdiction with respect to civil lawsuits brought against the United States for the recovery of taxes. Specifically, Section 1346(a)(1) provides as follows:
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