Shuja Qureshi v. United States Internal Revenue Service

WILLIAM A. NORRIS, Circuit Judge:

Shuja Qureshi seeks a refund of his 1983. taxes, which were collected by means of levies- on his wages and bank account. The Internal Revenue Service disallowed the taxpayer’s refund claim on the ground that it was untimely under 26 U.S.C. § 6511(a), which requires the claim to be brought within two years of the date the taxes were paid. The taxpayer then brought suit in the district court, which dismissed the complaint because a timely administrative claim is a jurisdictional prerequisite to a tax refund suit. On pro se appeal, the taxpayer contends that his…