Jane Flaster Kuznitsky, Formerly Known as Jane Flaster Biggard v. United States

RIPPLE, Circuit Judge.

Jane Kuznitsky appeals the district court’s dismissal of her case for lack of jurisdiction. Ms. Kuznitsky had sought a refund from the IRS for a penalty that it had assessed against her as a “responsible person” under 26 U.S.C. § 6672(a). The IRS disallowed her claim for refund, and she sought relief in the district court. The district court concluded that Ms. Kuznitsky had failed to file a timely claim for refund under 26 U.S.C. § 6611(a), and that this omission deprived the court of jurisdiction to hear her case. For the reasons that follow, we affirm the judgment of…