context: Danoff contends that the IRS should be equitably estopped from denying his refund claim because a IRS agents told him during a telephone inquiry that he had four years to file his tax return. Section 6511, however, is not subject to equitable exceptions.
citation_a.signal: see
citation_a.parenthetical: "Congress did not intend courts to read other unmentioned, open-ended, 'equitable' exceptions into the statute that it wrote."
citation_a.sentence: See United States v. Brockamp, 519 U.S. 347, 354, 117 S.Ct. 849, 136 L.Ed.2d 818 (1997), (“Congress did not intend courts to read other unmentioned, open-ended, ‘equitable’ exceptions into the statute that it wrote.”); see also Socop-Gonzalez v. INS, 272 F.3d 1176 (9th Cir.2001) (“[I]f a time limit is jurisdictional, it is not subject to the defenses of waiver, equitable tolling or equitable estoppel, although there may still be exceptions based on ‘unique circumstances’ ”).
citation_b.signal: see also
citation_b.parenthetical: "[I]f a time limit is jurisdictional, it is not subject to the defenses of waiver, equitable tolling or equitable estoppel, although there may still be exceptions based on 'unique circumstances' "
citation_b.sentence: See United States v. Brockamp, 519 U.S. 347, 354, 117 S.Ct. 849, 136 L.Ed.2d 818 (1997), (“Congress did not intend courts to read other unmentioned, open-ended, ‘equitable’ exceptions into the statute that it wrote.”); see also Socop-Gonzalez v. INS, 272 F.3d 1176 (9th Cir.2001) (“[I]f a time limit is jurisdictional, it is not subject to the defenses of waiver, equitable tolling or equitable estoppel, although there may still be exceptions based on ‘unique circumstances’ ”).