PALA, Inc. Employees Profit Sharing Plan & Trust Agreement v. United States

PATRICK E. HIGGINBOTHAM, Circuit Judge:

This case requires us to examine the nuances of the “informal claim” doctrine. Plaintiff-Appellant filed suit, requesting a tax refund from the Internal Revenue Service. Athough it never made a formal refund claim to the IRS, Plaintiff-Appellant asserts that it filed a timely “informal claim.” The district court dismissed for lack of subject matter jurisdiction, concluding that no timely claim was filed. Upon denial of its motion for reconsideration, Plaintiff-Appellant asks this Court to overturn the district court’s judgment of dismissal. We decline…