Libitzky v. United States

District Court, N.D. California·Decided March 2, 2023·No. 3:18-cv-00792·Unknown

Opinion

MOSES S. LIBITZKY and SUSAN M. Case No. 18-cv-00792-JD LIBITZKY, Plaintiffs, FINDINGS OF FACT AND v. UNITED STATES OF AMERICA, Defendant.

Married taxpayers Moses and Susan Libitzky filed this action against the United States for a “refund and credit for income taxes paid for the tax year 2011,” in the amount of $692,690. Dkt. No. 1 ¶¶ 1, 9; Dkt. No. 76 ¶ 1. The cross-motions for summary judgment were denied, Dkt. No. 57, and the case was tried by the Court pursuant to the parties’ stipulation to a non-jury trial under Federal Rule of Civil Procedure 39(a)(1). Dkt. No. 72. Over the course of the two-day bench trial, counsel for both sides examined witnesses, moved documents into evidence, and read deposition transcripts into the record. Dkt. Nos. 91, 92. After the close of evidence, the parties filed proposed findings of fact and conclusions of law, and the Court heard closing arguments. Dkt. Nos. 101, 102, 103. The Court makes the ensuing findings of fact and conclusions of law pursuant to Federal Rule of Civil Procedure 52(a)(1). In light of the evidence admitted at trial, the Court’s observation of the demeanor, credibility, and candor of the witnesses, and the arguments of the parties at trial and in post-trial filings, the Court finds that the Libitzkys did not make an adequate and timely refund or credit claim for their $692,690 payment for the 2011 tax year, and the case must be dismissed for lack of jurisdiction under 26 U.S.C. § 6511(b)(2)(A). The parties and the Court are deeply familiar with the facts and history of this case. The Libitzkys had a number of issues with their federal income taxes for the 2011, 2012, and 2013 tax years. The 2011 tax year is the one at issue in this case. As the Court noted in the summary judgment order, Dkt. No. 57, many of the key facts here are not disputed. The parties agree that: (1) the Libitzkys overpaid their taxes for the 2011 tax year by $692,690; (2) the Libitzkys’ 2011 tax year payments are legally deemed to have been made on April 17, 2012; and (3) the Libitzkys’ 2011 tax return was not deemed filed with the Internal Revenue Service (IRS) until January 20, 2016. The parties also agree that the Libitzkys’ late-filed 2011 tax return was their formal claim for a credit for the $692,690 overpayment. See also 26 C.F.R. § 301.6402-3(a)(1) (claim for credit or refund for overpaid income taxes should “[i]n general” be made “on the appropriate income tax return”). For the reasons the Court detailed in the summary judgment order, Dkt. No. 57, if the Libitzkys made a valid informal claim for refund or credit by October 17, 2015, they may recover the $692,690. If they did not, the overpayment is not recoverable, and the Court lacks jurisdiction over their claim. This is because under 26 U.S.C. § 7422, the United States has waived its sovereign immunity for civil refund actions where a claim for refund or credit has been “duly filed with the Secretary” of Treasury according to the relevant laws and regulations. Under 26 U.S.C. § 6511(a), refund or credit claims must be made “within 3 years from the time the return was filed, or 2 years from the time the tax was paid,” whichever is later. In any event, under 26 U.S.C. § 6511(b)(2)(A), “the amount of the credit or refund shall not exceed the portion of the tax paid within the period, immediately preceding the filing of the claim, equal to 3 years plus the period of any extension of time for filing the return.” The parties agree that this “look-back period” here was 3.5 years in length, so to have been timely under § 6511(b)(2)(A), the Libitzkys needed to file a claim for the $692,690 overpayment by October 17, 2015, which is 3.5 years from April 17, “§ 6511(b)(2)(A) is jurisdictional.” Zeier v. United States Internal Revenue Service, 80 F.3d 1360, 1364 (9th Cir. 1996). The agreements on the facts effectively narrowed the bench trial to this question: did the Libitzkys make an informal claim to the IRS by October 17, 2015, asking for a credit or refund for the $692,690 they overpaid for the 2011 tax year?1 They did not, for the reasons stated in the ensuing findings and conclusions. 1. Moses and Susan Libitzky are married taxpayers who, for all relevant years, filed their federal income tax returns jointly. Dkt. No. 76 (Joint Statement of Stipulated Facts, or JSF) ¶ 1; Dkt. Nos. 98 & 99 (Trial Tr.) at 15:9-11. 2. Moses Libitzky owns and operates the Libitzky Properties Companies, a small business engaged in real estate investment and management, with offices in Emeryville, California. JSF ¶ 2; Trial Tr. at 12:2-9. Susan Libitzky does not have any involvement in the business of Libitzky Properties, or play any role in the preparation of the Libitzkys’ personal income tax returns. Trial Tr. at 11:22-25, 14:10-12; JSF ¶ 27.2 3. The Libitzkys had a historical practice of overpaying their taxes, and electing to apply any overpayment credit for a given tax year to their tax liability for the following year. Trial Tr. at 25:14-19. 4. From 2009 to 2018, Mark Albrecht worked in-house for Libitzky Properties as a tax accountant responsible for preparing and filing tax returns, among other duties. JSF ¶ 3; Trial Tr. at 70:17-21, 114:6-8. Albrecht worked in close physical proximity to Libitzky in the Emeryville office, and the two men had frequent interactions throughout the day on accounting and tax matters. Trial Tr. at 13:18-14:2. In addition to handling Libitzky Properties’ business tax

1 The government made a rather cursory stab at suggesting that an informal claim needed to have been made by April 17, 2014, two years after the payments, but the Court rejected that theory in the summary judgment order, see Dkt. No. 57 at 5-6, and nothing new warrants a reconsideration.

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