Task: Wrong Candidate Generation
Input (English): tax return. We have jurisdiction under 28 U.S.C. § 1291. We review de novo, Cement Masons Health & Welfare Trust Fund for No. Calif. v. Stone, 197 F.3d 1003, 1005 (9th Cir.1999), and we affirm. The district court properly concluded that because Danoff did not file his claim for a tax refund within statutory three-year period, the refund claim was untimely under 26 U.S.C. § 6511(b). The district court therefore correctly concluded that it lacked subject matter jurisdiction over DanofPs tax refund action. See Imperial Plan, Inc. v. United States, 95 F.3d 25, 26 (9th Cir.1996) (affirming dismissal for lack of subject matter jurisdiction where taxpayer failed to file a timely administrative tax refund claim under section 6511); Zeier v. United States, 80 F.3d 1360, 1364 (9th Cir.1996) (<HOLDING>). Danoff contends that the IRS should be 
 Holding statements: (A) holding that  6511b2a is jurisdictional (B) holding that exhaustion is mandatory and jurisdictional (C) holding immunity from liability is not jurisdictional (D) recognizing that exhaustion is mandatory and jurisdictional (E) holding that exhaustion of issues is jurisdictional
Output (English): recognizing that exhaustion is mandatory and jurisdictional