Glenn E. Lovett v. United States

Opinion for the court filed by Circuit Judge NEWMAN. Separate concurring opinion filed by Circuit Judge MAYER.

NEWMAN, Circuit Judge.

Glenn E. Lovett appeals the decision of the United States Court of Federal Claims,1 dismissing his complaint for lack of subject matter jurisdiction. Acting on Mr. Lovett’s complaint, the court held that the three year statute of limitations had expired for a refund claim based on Mr. Lovett’s 1984 tax return. Mr. Lovett’s argument is that this 1984 tax was not required to be paid, that he was not aware of the error made in paying the tax until he learned in 1994…