Anastasoff v. United States

On April 13, 1996, Faye Anastasoff (plaintiff) mailed a claim to the Internal Revenue Service (IRS) (defendant) seeking a refund for overpaid taxes paid on April 15, 1993. The IRS received the claim on April 16, 1996. Section 6511(b) of the Internal Revenue Code required taxpayers to submit refund requests within three years of paying the subject taxes. Because Anastasoff’s claim was received three years and one day after she paid her taxes, the IRS denied her claim. Anastasoff argued that, under the mailbox rule codified in § 7502 of the Internal Revenue Code, the IRS should have accepted her claim because the claim was postmarked within the three-year period. In an unpublished opinion, Christie v. United States, No. 91-2375MN (1992), the United States Court of Appeals for the Eighth Circuit had previously held that § 7502 did not apply to refund claims that were mailed just before the three-year period stated in § 6511(b) ran out and were received after the three-year period expired. The district court held that § 7502 did not apply to Anastasoff’s claim. Anastasoff appealed to the Eighth Circuit, arguing that because Christie was an unpublished opinion, the Eighth Circuit was not bound to follow its decision in Christie. To make her argument, Anastasoff cited Eighth Circuit Rule 28A(i), which stated that unpublished opinions did not have precedential value.