No. 22-114
Mark Anthony Blommer v. Commissioner of Internal Revenue
Response Waived
Tags: administrative-law due-process irs irs-procedure non-statutory-notices statutory-compliance substitute-return substitutes-for-return tax-deficiency taxpayer-rights
Key Terms:
Privacy
Privacy
Latest Conference:
2022-10-07
Question Presented (AI Summary)
Whether a notice of deficiency must comply with applicable statutes to be valid
Question Presented (from Petition)
QUESTIONS PRESENTED 1. For a notice of deficiency to exist, must not said notices comply with the statutes? 2. If a taxpayer files a statement as instructed to by the Internal Revenue Service, is it lawful for the Internal Revenue Service to then file Form 1040 Substitutes for Return against a taxpayer. And is it lawful for the Internal Revenue Service to then create non statutory notices of deficiency based on those Form 1040 Substitutes for Return.
Docket Entries
2022-10-11
Petition DENIED.
2022-09-14
DISTRIBUTED for Conference of 10/7/2022.
2022-09-06
Waiver of right of respondent CIR to respond filed.
2022-06-01
Petition for a writ of certiorari filed. (Response due September 7, 2022)
Attorneys
CIR
Elizabeth B. Prelogar — Solicitor General, Respondent
Elizabeth B. Prelogar — Solicitor General, Respondent