All the tax sites and pundits are coming up with their year-end strategies; like old-time wedding regalia, some are old, some are new, some are borrowed, and maybe even some are blue. I’ll be in style, and offer a year-end tip with help from STJ Diana L. (“Sidewalks of New York”) Leyden.

Even if you’re not required to file a return (e.g., income under the wire), file anyway. If you don’t, the passage of time will bar your otherwise meritorious refund claim.

Just ask Mary C. deNourie, Docket No. 18182-22, filed 12/23/24. Mary’s income was Social Security and part-time retail clerking, so neither she nor spouse had filed for years. But IRS claimed she got some money from a LLC in year at issue, and hit her with a SND. She and IRS settled out the alleged deficiency at zero, but when Mary claimed a refund of withholding, IRS interposed Section 6511. Mary filed a return six years late claiming the refund, which IRS bounced. The Section 6511 three-and-two limits were long since passed.

STJ Di says it’s harsh but true. If you want a refund, even if you’re not required to file, you’d best file timely to claim it.

“As is true in many of the cases in this field, ‘[w]hile the result may seem harsh where the tax has actually been overpaid by withholding or payments of estimated tax, the result is mandated by the law and is also a problem of the taxpayer’s own creation.’ The situation is not an unfamiliar one, and has been before this Court in a variety of other circumstances.” Order, at p. 6. (Citations omitted).

A short form, like a 1040A or 1040-EZ, might do; try a LITC first. But file. Starts the SOL running, too. And tell ’em Mary sent ya.