1. “Statutory deadlines—like limitations periods—are mere non-jurisdictional ‘claim-processing rules’ unless Congress provides a clear statement that the rule is intended to have jurisdictional effect. Here, I.R.C. § 7422(a) provides that no suit for refund may be filed unless preceded by the filing of a refund claim with the IRS. I.R.C. § 6511(a), in turn, requires such refund claims to be filed within certain deadlines. Did the Court of Federal Claims below err by dismissing Dougherty Electric’s suit for lack of subject-matter jurisdiction for alleged failure to comply with I.R.C. § 7422(a) and § 6511(a)?”
2. “Refund claims are subject to a variety of equitable doctrines, including the informal claims doctrine, waiver, germaneness, the general claims doctrine, and equitable tolling. Under these doctrines, claims should not be rejected for technical deficiencies if those failings do not represent a substantial variance from the IRS’s preferred formal requirements. Here, Dougherty Electric’s timely informal submission put the IRS on notice of its claim and its subsequent amendment and formal claims provided all the information the IRS needed to reach the merits, which it did. Did the Court of Federal Clams below err by failing to apply the informal claim and other equitable doctrines to relate back the formal to the informal claim?”
