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Boechler, P.C. v. Commissioner of Internal Revenue
| Docket No. | Op. Below | Argument | Opinion | Vote | Author | Term |
|---|---|---|---|---|---|---|
| 20-1472 | 8th Cir. | Jan 12, 2022 | Apr 21, 2022 | 9-0 | Barrett | OT 2021 |
Holding: The 30-day time limit to file a petition for review of a collection due process determination under 26 U.S.C. § 6330(d)(1) is a non-jurisdictional deadline subject to equitable tolling.
Judgment: Reversed and remanded, 9-0, in an opinion by Justice Barrett on April 21, 2022.
SCOTUSblog Coverage
- Equitable tolling in a corner of the Internal Revenue Code (Susan C. Morse, April 25, 2022)
- Court rules unanimously that tax deadline is subject to equitable tolling (Susan C. Morse, April 21, 2022)
- Announcement of opinions for Thursday, April 21 (complete) (Angie Gou, April 21, 2022)
- Justices signal narrow support for allowing equitable tolling of tax deadline (Susan C. Morse, January 15, 2022)
- A tax deadline missed by one day leads to a showdown over equity, jurisdiction – and grammar (Susan C. Morse, January 11, 2022)
- Justices set January argument calendar (Amy Howe, November 18, 2021)
- Justices add five new cases to their docket from “long conference,” including Cruz campaign case (Amy Howe, September 30, 2021)
- Transparency, resentencing and preemption questions (Andrew Hamm, May 14, 2021)
| Date | Proceedings and Orders |
|---|---|
| Apr 16 2021 | Petition for a writ of certiorari filed. (Response due May 21, 2021) |
| May 12 2021 | Motion to extend the time to file a response from May 21, 2021 to June 21, 2021, submitted to The Clerk. |
| May 13 2021 | Motion to extend the time to file a response is granted and the time is extended to and including June 21, 2021. |
| May 18 2021 | Brief amicus curiae of The Center for Taxpayer Rights filed. |
| May 21 2021 | Brief amici curiae of Federal Tax Clinic at Charles Widger School of Law et al. filed. |
| Jun 11 2021 | Motion to extend the time to file a response from June 21, 2021 to July 22, 2021, submitted to The Clerk. |
| Jun 14 2021 | Motion to extend the time to file a response is granted and the time is further extended to and including July 22, 2021. |
| Jul 22 2021 | Brief of respondent Commissioner of Internal Revenue in opposition filed. |
| Aug 10 2021 | Reply of petitioner Boechler, P.C. filed. (Distributed) |
| Aug 11 2021 | DISTRIBUTED for Conference of 9/27/2021. |
| Sep 30 2021 | Petition GRANTED. |
| Nov 15 2021 | Joint appendix filed. (Statement of costs filed) |
| Nov 15 2021 | Brief of petitioner Boechler, P.C. filed. |
| Nov 17 2021 | ARGUMENT SET FOR Wednesday, January 12, 2022. |
| Nov 17 2021 | Record requested from the U.S.C.A. 8th Circuit. |
| Nov 22 2021 | Brief amici curiae of National Taxpayers Union Foundation, et al., filed. |
| Nov 22 2021 | Brief amici curiae of Federal Tax Clinics, Legal Aid Groups, and Tax Professors filed. |
| Nov 22 2021 | Brief amici curiae of The Center for Taxpayer Rights, et al. filed. |
| Nov 22 2021 | Amicus brief of A. Lavar Taylor not accepted for filing. (Corrected version submitted - December 01, 2021). |
| Nov 22 2021 | Brief amicus curiae of A. Lavar Taylor filed. |
| Dec 14 2021 | CIRCULATED |
| Dec 15 2021 | Brief of respondent Commissioner of Internal Revenue filed. (Distributed) |
| Dec 30 2021 | Reply of petitioner Boechler, P.C. filed. (Distributed) |
| Jan 10 2022 | Letter from Solicitor General regarding statistics in brief on the merits filed. (Distributed) |
| Jan 10 2022 | Restricted documents received from the U.S.C.A. has been electronically filed. |
| Jan 11 2022 | Record received from the U.S.C.A. 8th Circuit. 1 - Box |
| Jan 12 2022 | Argued. For petitioner: Melissa Arbus Sherry, Washington, D. C. For respondent: Jonathan C. Bond, Assistant to the Solicitor General, Department of Justice, Washington, D. C. |
| Apr 21 2022 | Judgment REVERSED and case REMANDED. Barrett, J., delivered the opinion for a unanimous Court. |
| May 23 2022 | Judgment Issued |
| Jan 11 2023 | Record returned to the U.S.C.A. 8th Circuit. 1 - Box. |
