are analogous, we are required to apply Mead’s standard of review to an IRS revenue ruling. See Matz v. Household Int’l Tax Reduction Investment Plan, 265 F.3d 572, 575 (7th Cir.2001). In light of the Supreme Court’s intervening holding in Mead, we must decide whether Revenue Ruling 76-511 commands deference. We believe it does. First, the IRS’s reasoning is valid. Although the IRS’s interpretation of I.R.C. § 6511(a) may render the statute’s time limitations somewhat “illusory,” the look-back provisions of I.R.C. § 6511(b) effectively eliminate any danger of taxpayers recovering on stale claims. Every appellate court that has addressed this issue has reached the same decision as the IRS or has indicated it would do so. See Weisbart v. United States, 222 F.3d 93, 95-96 (2d Cir.2000) (<HOLDING>); Richards v. C.I.R., 37 F.3d 587, 589 (10th
holding that the taxpayer met the claim requirement where the taxpayer first filed a timely letter with the irs that requested a refund and subsequently filed a formal refund claim holding a taxpayer has three years from the date his return is actually filed to file a claim for refund or credit holding that a taxpayer only has a refund right after the irs has credited the refund to other underpaid taxes therefore the refund was not part of the bankruptcy estate holding statute of limitations should not be equitably tolled for taxpayer who filed a refund claim after the applicable statute of limitations holding under section 7422a that the district court lacked jurisdiction over a taxpayers refund claim because the taxpayer failed to file a refund claim before the statute of limitations had run