No. 20-1031

Northern California Small Business Assistants, Inc. v. Commissioner of Internal Revenue

Lower Court: Ninth Circuit
Docketed: 2021-01-28
Status: Denied
Type: Paid
Amici (1)
Tags: administrative-procedure civil-procedure equitable-tolling jurisdiction jurisdictional-deadline statutory-interpretation supreme-court supreme-court-precedent tax-law
Key Terms:
Securities JusticiabilityDoctri
Latest Conference: 2021-04-30
Related Cases: 20-1014 (Vide)
Question Presented (AI Summary)

Is 26 U.S.C. § 6213(a)'s deficiency petition (90-day) filing deadline jurisdictional

Question Presented (from Petition)

QUESTION PRESENTED L Is 26 U.S.C. § 6213(a)’s deficiency petition (90-day) Filing Deadline jurisdictional (such that it is not subject to equitable tolling) under current Supreme Court case law?

Docket Entries

2021-05-03
Petition DENIED.
2021-04-14
DISTRIBUTED for Conference of 4/30/2021.
2021-04-14
Reply of petitioner Northern California Small Business Assistants, Inc. submitted.
2021-02-15
Brief amicus curiae of The Center for Taxpayer Rights filed.
2021-02-02
Motion to extend the time to file a response is granted and the time is extended to and including March 31, 2021.
2021-02-01
Motion to extend the time to file a response from March 1, 2021 to March 31, 2021, submitted to The Clerk.
2021-01-25
Petition for a writ of certiorari filed. (Response due March 1, 2021)

Attorneys

Commissioner of Internal Revenue
Edwin Smiley KneedlerD.O.J., Respondent
Edwin Smiley KneedlerD.O.J., Respondent
Northern California Small Business Assistants, Inc.
Douglas Leland YoumansWagner Kirkman Blaine Klomparens & Youmans, LLP, Petitioner
Douglas Leland YoumansWagner Kirkman Blaine Klomparens & Youmans, LLP, Petitioner
The Center for Taxpayer Rights
Carlton M. SmithAttorney at Law, Amicus
Carlton M. SmithAttorney at Law, Amicus