In Re: Roger Pransky, Debtor Internal Revenue Service v. Roger Pransky

OPINION OF THE COURT

AMBRO, Circuit Judge.

Roger Pransky appeals the District Court’s determination that he failed to initiate in a timely manner this adversary proceeding against the Internal Revenue Service, as required to invoke the Bankruptcy Court’s jurisdiction pursuant to 26 U.S.C. § 6532(a)(1). Section 6532 sets a two-year statute of limitations to file suit in court when the IRS disallows a taxpayer’s request for a tax refund. Because Pransky did not bring suit within § 6532’s two-year window of opportunity following the IRS’s disallowance of his refund requests for tax years 1984 and…