Whether Section 6501(c)(1) allows the IRS to assess taxes beyond the standard three-year limitations period when a taxpayer's preparer filed a fraudulent return without the taxpayer's knowledge or intent

here is whether the IRS can assess taxes beyond the usual three-year deadline when the taxpayer’s preparer intended to file a false or fraudulent return, but the taxpayer herself had no such intent and no knowledge of any wrongdoing. The legal and practical stakes are both significant and obvious. If read too broadly, this draconian provision can destroy repose, eliminate a taxpayer’s fresh start, and unexpectedly trap innocent parties with sudden (and crushing) debt—all while excusing tardy government action and encouraging potential IRS mischief. Yet in the proceedings below, the Third Circuit nonetheless adopted the IRS’s position. In doing so, it exposed Murrin to staggering taxes and interest for returns filed over two decades in the past—without any indication she had a clue the returns were flawed. In reaching that conclusion, the Third Circuit squarely rejected a contrary 2-1 decision of the Federal Circuit on the identical question. App., infra, 15a (“our holding today departs from the Federal Circuit[]”). That stark contrast leaves the nationwide application of the federal tax code in disarray: high-income taxpayers can litigate in the U.S. Court of Federal Claims (where they will win under Federal Circuit authority), while any litigant stuck in U.S. Tax Court could now lose under the Third Circuit’s opposite position.2 That open division is intolerable in a scheme that demands uniformity. This question, unfortunately, arises frequently, and it is being closely watched by the tax community. Expert commentators have flagged the Third Circuit’s decision as one of the year’s “most significant federal tax decisions” (A. Farrell, Top Federal Tax Decisions of 2005, Law360 (Dec. 23, 2025) and major stakeholders participated as amicus curiae at the circuit level, reflecting the issue’s obvious importance. This single statutory question is a pure question of law, was below, and will arrive here in a clean vehicle. This case presents the ideal opportunity for this Court to resolve whether innocent taxpayers can face IRS demands years (or even many decades) after-the-fact—or whether Section 6501(c)(1)’s narrow allowance is indeed limited to those taxpayers who themselves engaged in actual wrongdoing. 2. This case arose from the government’s attempt to assess new taxes on a series of Murrin’s returns filed over two decades ago (1993-1999). App., infra, 3a. On the key stipulated facts, Murrin’s tax preparer “placed false or fraudulent entries on Murrin’s tax returns with an intent to evade tax” (ibid.), but Murrin herself neither 2 This disparity is a result of the specific rules for filing a refund claim in the Court of Claims: the taxpayer must first pay the full disputed tax before filing suit. See 28 U.S.C. 1346(a)(1); 28 U.S.C. 1491(a). That option is often not available as a practical matter to lower-income taxpayers, especially once the IRS tacks on interest accruing for years. knew of the fraud nor intended to evade tax (ibid.). About a quarter-century later, the IRS issued a notice of deficiency targeting “underpayments” on those stale returns. Jbid. Murrin contested the IRS’s action in tax court, admitting the $65,318 in unpaid taxes but contesting the timeliness of the IRS’s action. Ibid. (invoking Section 6501(a)’s three-year limitations period). Despite all sides agreeing that Murrin herself did nothing wrong, the tax court held that Section 6501(c)(1) excused the IRS’s delay because Murrin’s tax preparer (unbeknownst to her) intentionally “prepared * * * false or fraudulent tax returns with an intent to evade tax.” Ibid.; see also id. at 35a-36a. 3. a. The Third Circuit affirmed. App., infra, 18a-34a. The court initially confirmed the appeal “turns on” a single legal question: “our interpretation of § 6501.” Id. at 21a. In analyzing that provision, the court recognized Murrin’s position “is a fair one,” and it “underst[o