Boechler, P.C. v. Commissioner of Internal Revenue, No. 20-1472 [Arg: 1.12.2022]
Whether the 30-day time limit to file a petition for review in the Tax Court of a notice of determination from the commissioner of internal revenue in 26 U.S.C. § 6330(d)(1) is a jurisdictional requirement or a claim-processing rule subject to equitable tolling.
QUESTION PRESENTED:
Whether the 30-day time limit to file a petition for review in the Tax Court of a notice of determination from the commissioner of internal revenue in 26 U.S.C. § 6330(d)(1) is a jurisdictional requirement or a claim-processing rule subject to equitable tolling.
Date Proceedings and Orders (key to color coding)
Apr 16 2021 | Petition for a writ of certiorari filed. (Response due May 21, 2021)
May 12 2021 | Motion to extend the time to file a response from May 21, 2021 to June 21, 2021, submitted to The Clerk.
May 13 2021 | Motion to extend the time to file a response is granted and the time is extended to and including June 21, 2021.
May 18 2021 | Brief amicus curiae of The Center for Taxpayer Rights filed.
May 21 2021 | Brief amici curiae of Federal Tax Clinic at Charles Widger School of Law et al. filed.
Jun 11 2021 | Motion to extend the time to file a response from June 21, 2021 to July 22, 2021, submitted to The Clerk.
Jun 14 2021 | Motion to extend the time to file a response is granted and the time is further extended to and including July 22, 2021.
Jul 22 2021 | Brief of respondent Commissioner of Internal Revenue in opposition filed.
Aug 10 2021 | Reply of petitioner Boechler, P.C. filed. (Distributed)
Aug 11 2021 | DISTRIBUTED for Conference of 9/27/2021.
Sep 30 2021 | Petition GRANTED.
Nov 15 2021 | Joint appendix filed. (Statement of costs filed)
Nov 15 2021 | Brief of petitioner Boechler, P.C. filed.
Nov 17 2021 | ARGUMENT SET FOR Wednesday, January 12, 2022.
Nov 17 2021 | Record requested from the U.S.C.A. 8th Circuit.
Nov 22 2021 | Brief amici curiae of National Taxpayers Union Foundation, et al., filed.
Nov 22 2021 | Brief amici curiae of Federal Tax Clinics, Legal Aid Groups, and Tax Professors filed.
Nov 22 2021 | Brief amici curiae of The Center for Taxpayer Rights, et al. filed.
Nov 22 2021 | Amicus brief of A. Lavar Taylor not accepted for filing. (Corrected version submitted - December 01, 2021).
Nov 22 2021 | Brief amicus curiae of A. Lavar Taylor filed.
Dec 14 2021 | CIRCULATED
Dec 15 2021 | Brief of respondent Commissioner of Internal Revenue filed. (Distributed)
Dec 30 2021 | Reply of petitioner Boechler, P.C. filed. (Distributed)
Jan 10 2022 | Letter from Solicitor General regarding statistics in brief on the merits filed. (Distributed)
Jan 11 2022 | Record received from the U.S.C.A. 8th Circuit. 1 - Box
Jan 12 2022 | Argued. For petitioner: Melissa Arbus Sherry, Washington, D. C. For respondent: Jonathan C. Bond, Assistant to the Solicitor General, Department of Justice, Washington, D. C.
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Whether the 30-day time limit to file a petition for review in the Tax Court of a notice of determination from the commissioner of internal revenue in 26 U.S.C. § 6330(d)(1) is a jurisdictional requirement or a claim-processing rule subject to equitable tolling.
Date Proceedings and Orders (key to color coding)
Apr 16 2021 | Petition for a writ of certiorari filed. (Response due May 21, 2021)
May 12 2021 | Motion to extend the time to file a response from May 21, 2021 to June 21, 2021, submitted to The Clerk.
May 13 2021 | Motion to extend the time to file a response is granted and the time is extended to and including June 21, 2021.
May 18 2021 | Brief amicus curiae of The Center for Taxpayer Rights filed.
May 21 2021 | Brief amici curiae of Federal Tax Clinic at Charles Widger School of Law et al. filed.
Jun 11 2021 | Motion to extend the time to file a response from June 21, 2021 to July 22, 2021, submitted to The Clerk.
Jun 14 2021 | Motion to extend the time to file a response is granted and the time is further extended to and including July 22, 2021.
Jul 22 2021 | Brief of respondent Commissioner of Internal Revenue in opposition filed.
Aug 10 2021 | Reply of petitioner Boechler, P.C. filed. (Distributed)
Aug 11 2021 | DISTRIBUTED for Conference of 9/27/2021.
Sep 30 2021 | Petition GRANTED.
Nov 15 2021 | Joint appendix filed. (Statement of costs filed)
Nov 15 2021 | Brief of petitioner Boechler, P.C. filed.
Nov 17 2021 | ARGUMENT SET FOR Wednesday, January 12, 2022.
Nov 17 2021 | Record requested from the U.S.C.A. 8th Circuit.
Nov 22 2021 | Brief amici curiae of National Taxpayers Union Foundation, et al., filed.
Nov 22 2021 | Brief amici curiae of Federal Tax Clinics, Legal Aid Groups, and Tax Professors filed.
Nov 22 2021 | Brief amici curiae of The Center for Taxpayer Rights, et al. filed.
Nov 22 2021 | Amicus brief of A. Lavar Taylor not accepted for filing. (Corrected version submitted - December 01, 2021).
Nov 22 2021 | Brief amicus curiae of A. Lavar Taylor filed.
Dec 14 2021 | CIRCULATED
Dec 15 2021 | Brief of respondent Commissioner of Internal Revenue filed. (Distributed)
Dec 30 2021 | Reply of petitioner Boechler, P.C. filed. (Distributed)
Jan 10 2022 | Letter from Solicitor General regarding statistics in brief on the merits filed. (Distributed)
Jan 11 2022 | Record received from the U.S.C.A. 8th Circuit. 1 - Box
Jan 12 2022 | Argued. For petitioner: Melissa Arbus Sherry, Washington, D. C. For respondent: Jonathan C. Bond, Assistant to the Solicitor General, Department of Justice, Washington, D. C.
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