Court holds refund claims were not duly filed

After requesting a review by the IRS Office of Appeals, the Browns filed a complaint with the Court of Federal Claims, asserting a tax refund claim for 2015 and 2017 based on the foreign earned income exclusion under Sec. 911(a). [...]they argued that the requirement that the taxpayer personally sign his or her returns, and if they are signed by an agent, that a power of attorney must accompany the return, is created by Regs. Sec. 301.6402-2(b)(l), and the signature requirements were statutory and thus could not be waived, citing Turks Head Club v. Broderick, 166 F.2d 877 (1st Cir. 1948); Oplin, 270 F.3d 1297 (10th Cir. 2001); and two of its own recent opinions, Dixon, 147 Fed. Because the court found the Browns' amended returns were not duly filed under Sec. 7422(a), the court held it lacked jurisdiction over the Browns' complaint.