No. 25-988
Stephanie Murrin v. Commissioner of Internal Revenue
Amici (3)
Experienced Counsel
Tags: circuit-split innocent-taxpayer-liability internal-revenue-code statute-of-limitations tax-assessment-limitations tax-fraud
Latest Conference:
N/A
Question Presented (from Petition)
Whether, under 26 U.S.C. § 6501(c)(1), the IRS may assess tax beyond the Code's three-year limitations period based solely on the fraudulent intent of a third-party, even when the taxpayer herself neither intended to evade tax nor knew of any wrongdoing.
Question Presented (AI Summary)
Whether, under 26 U.S.C. § 6501(c)(1), the IRS may assess tax beyond the Code's three-year limitations period based solely on the fraudulent intent of a third-party tax return preparer, even when the taxpayer herself neither intended to evade tax nor knew of any wrongdoing
Docket Entries
2026-03-23
Motion to extend the time to file a response is granted and the time is extended to and including April 22, 2026.
2026-03-23
Amicus brief of The American College of Tax Counsel submitted.
2026-03-23
Amicus brief of Tax Litigation Clinic of the Legal Services Center of Harvard Law School submitted.
2026-03-23
Amicus brief of Center for Taxpayer Rights submitted.
2026-03-23
Brief amicus curiae of Tax Litigation Clinic of the Legal Services Center of Harvard Law School filed.
2026-03-23
Brief amicus curiae of The American College of Tax Counsel filed.
2026-03-23
Brief amicus curiae of Center for Taxpayer Rights filed.
2026-03-20
Motion of Commissioner of Internal Revenue for an extension of time submitted.
2026-03-20
Motion to extend the time to file a response from March 23, 2026 to April 22, 2026, submitted to The Clerk.
2026-02-17
Petition for a writ of certiorari filed. (Response due March 23, 2026)
2026-01-06
Application (25A778) granted by Justice Alito extending the time to file until February 17, 2026.
2025-12-31
Application (25A778) to extend the time to file a petition for a writ of certiorari from January 15, 2026 to February 17, 2026, submitted to Justice Alito.
Attorneys
Center for Taxpayer Rights
Guinevere M. Moore — Moore Tax Law Group, LLC, Amicus
Commissioner of Internal Revenue
D. John Sauer — Solicitor General, Respondent
Stephanie Murrin
Anne Margaret Voigts — Pillsbury Winthrop Shaw Pittman LLP, Petitioner
Tax Litigation Clinic of the Legal Services Center of Harvard Law School
Kelley Cooper Miller — Loeb and Loeb, LLP, Amicus
Kelley Cooper Miller — Loeb and Loeb, LLP, Petitioner
The American College of Tax Counsel
Caroline DeLisle Ciraolo — Kostelanetz LLP, Amicus