No. 21-490

Judith S. Coffey, et al. v. Commissioner of Internal Revenue

Lower Court: Eighth Circuit
Docketed: 2021-10-04
Status: Denied
Type: Paid
Tags: even if it is subsequently determined that the ta assessment-period bona-fide-resident internal-revenue-code section-6501(a) section-932(c)(2) statute-of-limitations tax-filing tax-return u.s.-virgin-islands
Key Terms:
Securities Privacy
Latest Conference: 2022-01-07
Question Presented (from Petition)

Whether a Form 1040 (U.S. Individual Income Tax Return) filed with the U.S. Virgin Islands Bureau of Internal Revenue ("VIBIR") pursuant to Section 932(c)(2) is the "return required to be filed by the taxpayer" commencing the statute of limitations on assessment under Section 6501(a), even if it is subsequently determined that the taxpayer was not a bona fide resident of the Virgin Islands.

Question Presented (AI Summary)

Whether a Form 1040 (U.S. Individual Income Tax Return) filed with the U.S. Virgin Islands Bureau of Internal Revenue (VIBIR") pursuant to Section 932(c) (2) is the 'return required to be filed by the taxpayer' commencing the statute of limitations on assessment under Section 6501(a)

Docket Entries

2022-01-10
Petition DENIED.
2021-12-22
DISTRIBUTED for Conference of 1/7/2022.
2021-12-17
Reply of petitioners Judith S. Coffey, et al. filed.
2021-12-08
Brief for the Respondent filed.
2021-11-19
Motion to extend the time to file a response is granted and the time is further extended to and including December 8, 2021.
2021-11-18
Motion to extend the time to file a response from December 3, 2021 to December 8, 2021, submitted to The Clerk.
2021-11-01
Motion to extend the time to file a response is granted and the time is extended to and including December 3, 2021.
2021-10-29
Motion to extend the time to file a response from November 3, 2021 to December 3, 2021, submitted to The Clerk.
2021-09-30
Petition for a writ of certiorari filed. (Response due November 3, 2021)

Attorneys

Commissioner of Internal Revenue
Elizabeth B. PrelogarSolicitor General, Respondent
Judith S. Coffey, et al.
Randall Paul AndreozziAndreozzi Bluestein, LLP, Petitioner