Shuja Qureshi v. United States Internal Revenue Service

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 administrative claim was timely because the statute of limitations begins to run only when the taxpayer receives notice that his taxes have been paid in full and the tax lien has been released. We affirm.

I

Shuja Qureshi (taxpayer) filed his 1983 U.S. Individual Income Tax Return (Form 1040) on June 15, 1984. After the Internal Revenue Service (IRS) determined that the taxpayer had not substantiated some of the claimed deductions and adjustments on his return, it assessed a deficiency in the amount of $15,142, plus $4,694.39 in interest. The taxpayer did not pay the amount assessed against him, and the IRS proceeded to…