No. 22-9
Whirlpool Financial Corporation, et al. v. Commissioner of Internal Revenue
Tags: administrative-law income-taxation internal-revenue-code regulations sixth-circuit sixth-circuit-precedent statutory-interpretation tax-court tax-law treasury-regulations
Latest Conference:
2022-11-18
(distributed 2 times)
Question Presented (from Petition)
Whether the divided Sixth Circuit properly held—in conflict with precedent of this Court and settled administrative-law principles—that a statute that is conditioned on regulations delineating its reach may be enforced without regard to those regulations?
Question Presented (AI Summary)
Whether the divided Sixth Circuit properly held that a statute conditioned on regulations delineating its reach may be enforced without regard to those regulations
Docket Entries
2022-11-21
Petition DENIED.
2022-11-02
DISTRIBUTED for Conference of 11/18/2022.
2022-11-02
Reply of petitioners Whirlpool Financial Corporation, et al. filed. (Distributed)
2022-10-19
Brief of respondent Commissioner of Internal Revenue in opposition filed.
2022-09-08
Motion to extend the time to file a response is granted and the time is extended to and including October 19, 2022.
2022-09-07
Motion to extend the time to file a response from September 19, 2022 to October 19, 2022, submitted to The Clerk.
2022-08-18
Response Requested. (Due September 19, 2022)
2022-08-10
DISTRIBUTED for Conference of 9/28/2022.
2022-08-04
Brief amici curiae of PricewaterhouseCoopers LLP, et al. filed.
2022-08-04
Brief amici curiae of Silicon Valley Tax Directors Group, et al. filed.
2022-08-03
Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
2022-08-03
Brief amicus curiae of The National Association of Manufacturers filed.
2022-06-30
Petition for a writ of certiorari filed. (Response due August 4, 2022)
2022-05-13
Application (21A713) granted by Justice Kavanaugh extending the time to file until June 30, 2022.
2022-05-10
Application (21A713) to extend the time to file a petition for a writ of certiorari from May 31, 2022 to June 30, 2022, submitted to Justice Kavanaugh.
Attorneys
Commissioner of Internal Revenue
Elizabeth B. Prelogar — Solicitor General, Respondent
PricewaterhouseCoopers LLP, Deloitte Tax LLP, & KPMG LLP
Silicon Valley Tax Directors Group, et al.
David B. Salmons — Morgan, Lewis & Bockius LLP, Amicus
The National Association of Manufacturers
Lowell Dean Yoder — McDermott Will & Emery LLP, Amicus
Whirlpool Financial Corporation, et al.
Gregory George Garre — Latham & Watkins LLP, Petitioner