No. 25A778

Stephanie Murrin v. Commissioner of Internal Revenue

Lower Court: Third Circuit
Docketed: 2026-01-05
Status: Application
Type: A
Experienced Counsel
Tags: innocent-taxpayer iRS-assessment limitations-period section-6501 tax-court tax-fraud
Key Terms:
Privacy
Latest Conference: N/A
Question Presented (from Petition)

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.

Question Presented (AI Summary)

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

Docket Entries

2026-01-06
Application (25A778) granted by Justice Alito extending the time to file until February 17, 2026.
2025-12-31
Application (25A778) to extend the time to file a petition for a writ of certiorari from January 15, 2026 to February 17, 2026, submitted to Justice Alito.

Attorneys

CIR
D. John SauerSolicitor General, Respondent
Stephanie Murrin
Anne Margaret VoigtsPillsbury Winthrop Shaw Pittman LLP, Petitioner