Weston v. United States
22-1179
| Fed. Cir. | Apr 13, 2022Background
- Weston filed paper federal income tax returns for 2012 and 2013 on Aug. 28, 2017, seeking refunds for overpayments.
- IRS mailed notices of disallowance by certified mail: for the 2013 claim on Apr. 4, 2018, and for the 2012 claim on Apr. 11, 2018; each notice advised a two‑year limitations period to sue under 26 U.S.C. § 6532(a)(1).
- Weston mailed her complaint to the U.S. Court of Federal Claims by certified mail on Apr. 11, 2020 (postmark that date); the court received and docketed the complaint on Apr. 20, 2020.
- The Government moved to dismiss for lack of subject matter jurisdiction because the complaint was filed after the two‑year period in § 6532(a)(1).
- Weston argued the § 7502(a)(1) mailbox rule made her Apr. 11, 2020 mailing the effective filing date; the Claims Court rejected that argument and dismissed for lack of jurisdiction.
- The Federal Circuit affirmed, holding § 7502’s mailbox rule does not apply to filings in courts other than the Tax Court and the Claims Court treats a civil action as commenced only upon actual filing/receipt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 26 U.S.C. § 7502(a)(1) (mailbox rule) makes a timely‑mailed complaint to the Court of Federal Claims timely for purposes of § 6532(a)(1) | Weston: certified‑mail postmark of Apr. 11, 2020 = timely filing | U.S.: § 7502 does not apply to documents filed in courts other than the Tax Court | Mailbox rule does not apply to Claims Court filings; mailing date not deemed filing date |
| Whether the Claims Court had subject matter jurisdiction under § 6532(a)(1) | Weston: timely mailing preserved jurisdiction | U.S.: complaint was not filed within two‑year period, so no jurisdiction | Claims Court lacked jurisdiction; dismissal affirmed |
Key Cases Cited
- RHI Holdings, Inc. v. United States, 142 F.3d 1459 (Fed. Cir. 1998) (failure to file timely complaint under § 6532 deprives Claims Court of jurisdiction)
- Kaffenberger v. United States, 314 F.3d 944 (8th Cir. 2003) (same principle on § 6532 timeliness and jurisdiction)
- In re Pransky, 318 F.3d 536 (3d Cir. 2003) (same principle on § 6532 timeliness and jurisdiction)
- Ohio Nat’l Life Ins. Co. v. United States, 922 F.2d 320 (6th Cir. 1990) (same principle on § 6532 timeliness and jurisdiction)
- Taylor v. United States, [citation="616 F. App'x 423"] (Fed. Cir. 2015) (pro se leniency cannot overcome jurisdictional time limits)