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 (from Petition)

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?

Question Presented (AI Summary)

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

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.
Main DocumentCertificate of Word CountProof of Service
2021-02-15
Brief amicus curiae of The Center for Taxpayer Rights filed.
Main DocumentCertificate of Word CountProof of Service
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.
Main Document
2021-01-25
Petition for a writ of certiorari filed. (Response due March 1, 2021)
PetitionAppendixCertificate of Word CountProof of Service

Attorneys

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