No. 23-125
Seaview Trading, LLC, AGK Investments, LLC, Tax Matters Partner v. Commissioner of Internal Revenue
Tags: administrative-law civil-procedure delinquent-returns filing-requirements legal-definition statutory-interpretation tax-code treasury-regulations
Key Terms:
AdministrativeLaw
AdministrativeLaw
Latest Conference:
2024-01-05
(distributed 2 times)
Question Presented (AI Summary)
Whether the word 'file' in 26 U.S.C. § 6229 (2000) and as used throughout the Tax Code carries its ordinary meaning for delinquent tax returns when no regulation specifies how to file delinquent returns
Question Presented (OCR Extract)
QUESTION PRESENTED Whether the word “file” in 26 U.S.C. § 6229 (2000) and as used throughout the Tax Code carries its ordinary meaning for delinquent tax returns when no regulation specifies how to file delinquent returns. (I)
Docket Entries
2024-01-08
Petition DENIED.
2023-11-29
DISTRIBUTED for Conference of 1/5/2024.
2023-11-29
Reply of petitioner Seaview Trading, LLC, AGK Investments, LLC, Tax Matters Partner filed. (Distributed)
2023-11-15
Brief of respondent Commissioner of Internal Revenue in opposition filed.
2023-10-11
Motion to extend the time to file a response is granted and the time is extended to and including November 15, 2023.
2023-10-10
Motion to extend the time to file a response from October 16, 2023 to November 15, 2023, submitted to The Clerk.
2023-09-14
Response Requested. (Due October 16, 2023)
2023-09-13
DISTRIBUTED for Conference of 10/6/2023.
2023-09-08
Brief amicus curiae of National Taxpayers Union Foundation filed.
2023-09-08
Brief amicus curiae of Center for Taxpayer Rights filed.
2023-09-05
Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
2023-08-07
Petition for a writ of certiorari filed. (Response due September 8, 2023)
2023-05-10
Application (22A982) granted by Justice Kagan extending the time to file until August 7, 2023.
2023-05-05
Application (22A982) to extend the time to file a petition for a writ of certiorari from June 8, 2023 to August 7, 2023, submitted to Justice Kagan.
Attorneys
Center for Taxpayer Rights
Commissioner of Internal Revenue
Elizabeth B. Prelogar — Solicitor General, Respondent
Elizabeth B. Prelogar — Solicitor General, Respondent
National Taxpayers Union Foundation
Seaview Trading, LLC, AGK Investments, LLC, Tax Matters Partner
Lisa S. Blatt — Williams & Connolly LLP, Petitioner
Lisa S. Blatt — Williams & Connolly LLP, Petitioner
Lisa Schiavo Blatt — Williams & Connolly LLP, Petitioner