Question Presented (from Petition)
1. Whether 26 U.S.C. 6213(a) grants the Tax Court jurisdiction to review an untimely petition for redetermination of a tax deficiency?
2. Even assuming that the Tax Court has jurisdiction to review some untimely petitions for redetermination of tax deficiencies, whether that jurisdiction extends to a petition filed after the Internal Revenue Service has already assessed the previously determined deficiency, as it is required to do under 26 U.S.C. 6213(c) "if the taxpayer does not file a petition with the Tax Court within the time prescribed."
Question Presented (AI Summary)
Whether 26 U.S.C. 6213(a) grants the Tax Court jurisdiction to review an untimely petition for redetermination of a tax deficiency?
2024-06-04
DISTRIBUTED for Conference of 6/20/2024.
2024-06-04
Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)
2024-05-20
Brief of respondents Isobel Berry Culp, et vir in opposition filed.
2024-04-01
Motion to extend the time to file a response is granted and the time is extended to and including May 20, 2024.
2024-03-29
Motion to extend the time to file a response from April 18, 2024 to May 20, 2024, submitted to The Clerk.
2024-03-19
Petition for a writ of certiorari filed. (Response due April 18, 2024)
2024-02-09
Application (23A738) granted by Justice Alito extending the time to file until March 19, 2024.
2024-02-07
Application (23A738) to extend the time to file a petition for a writ of certiorari from February 26, 2024 to March 19, 2024, submitted to Justice Alito.