CIC Services, LLC v. Internal Revenue Service
Holding
A suit to enjoin IRS Notice 2016-66 does not trigger the Anti-Injunction Act even though a violation of the notice may result in a tax penalty.
Judgment
Reversed and remanded, 9-0, in an opinion by Elena Kagan on May 17, 2021. Justice Sotomayor and Justice Kavanaugh filed concurring opinions.
Oct 21, 2019Application (19A440) to extend the time to file a petition for a writ of certiorari from November 26, 2019 to January 3, 2020, submitted to Justice Sotomayor.
Oct 28, 2019Application (19A440) granted by Justice Sotomayor extending the time to file until January 3, 2020.
Dec 13, 2019Application (19A440) to extend further the time from January 3, 2020 to January 17, 2020, submitted to Justice Sotomayor.Dec 17, 2019Application (19A440) granted by Justice Sotomayor extending the time to file until January 17, 2020.
Jan 17, 2020Petition for a writ of certiorari filed. (Response due February 24, 2020)Feb 14, 2020Brief amicus curiae of American College of Tax Counsel filed.Feb 18, 2020Brief amicus curiae of Tax Clinic at the Legal Services Center of Harvard Law School filed.Feb 19, 2020Motion to extend the time to file a response from February 24, 2020 to March 25, 2020, submitted to The Clerk.Feb 19, 2020Brief amicus curiae of Patrick J. Smith filed.Feb 20, 2020Motion to extend the time to file a response is granted and the time is extended to and including March 25, 2020.
Feb 21, 2020Brief amicus curiae of Americans for Prosperity Foundation filed.Feb 24, 2020Brief amicus curiae of Chamber of Commerce of the United States of America filed.Feb 24, 2020Brief amicus curiae of The Cato Institute filed.Feb 24, 2020Brief amicus curiae of Kristin E. Hickman filed.Feb 24, 2020Brief amici curiae of Kentucky Captive Association, Inc., et al. filed.Mar 25, 2020Brief of respondent Internal Revenue Service in opposition filed.Apr 3, 2020Reply of petitioner CIC Services, LLC filed.Apr 8, 2020DISTRIBUTED for Conference of 4/24/2020.
Apr 27, 2020DISTRIBUTED for Conference of 5/1/2020.
May 4, 2020Petition GRANTED.
May 18, 2020Joint motion of the parties for an extension of time to file the briefs on the merits filed.May 28, 2020Joint motion of the parties to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioner's brief on the merits is extended to and including July 15, 2020. The time to file respondents' brief on the merits is extended to and including September 8, 2020.
May 28, 2020Blanket Consent filed by Petitioner, CIC Services, LLCJul 6, 2020Motion to dispense with printing the joint appendix filed by petitioner CIC Services, LLC.Jul 14, 2020Brief amicus curiae of Center for Taxpayer Rights filed.Jul 15, 2020Brief of petitioner CIC Services, LLC filed.Jul 16, 2020Brief amicus curiae of Patrick J. Smith filed.Jul 22, 2020Brief amicus curiae of Americans for Prosperity Foundation filed.Jul 22, 2020Brief amicus curiae of Chamber of Commerce of the United States of America filed.Jul 22, 2020Brief amicus curiae of American College of Tax Counsel filed.Jul 22, 2020Brief amici curiae of National Federation of Independent Business Small Business Legal Center, et al. filed.Jul 22, 2020Motion for leave to file amicus brief filed by Institute for Free Speech (7/31/2020).Jul 22, 2020Amicus brief of Institute for Free Speech not accepted for filing. (July 28, 2020 - Corrected version submitted).
Jul 22, 2020Brief amicus curiae of Kristin E. Hickman filed.Jul 22, 2020Brief amici curiae of Alabama Captive Insurance Association, Inc., et al. filed.Jul 22, 2020Amicus brief of Partnership for Conservation not accepted for filing. (July 31, 2020 - Corrected version submitted)
Jul 22, 2020Brief amicus curiae of National Taxpayers Union Foundation filed.Jul 28, 2020Motion for leave to file amicus brief out of time filed by Partnership for Conservation (7/31/2020).Aug 11, 2020Brief amicus curiae of Professor Bryan T. Camp filed.Aug 24, 2020Motion to dispense with printing the joint appendix filed by petitioner GRANTED.
Sep 8, 2020Brief of respondent Internal Revenue Service filed.Sep 11, 2020Motion for leave to file amicus brief filed by Institute for Free Speech GRANTED.
Sep 11, 2020Motion for leave to file amicus brief out of time filed by Partnership for Conservation GRANTED.
Sep 15, 2020Brief amici curiae of Former Government Officials filed.Sep 16, 2020SET FOR ARGUMENT on Tuesday, December 1, 2020.
Oct 8, 2020Record requested from the U.S.C.A. 6th Circuit.
Oct 8, 2020Reply of petitioner CIC Services, LLC filed.Oct 8, 2020The record received from the U.S.C.A. 6th Circuit has been electronically filed.
Oct 27, 2020CIRCULATED
Dec 1, 2020Argued. For petitioner: Cameron T. Norris, Arlington, Va. For respondents: Jonathan C. Bond, Assistant to the Solicitor General, Department of Justice, Washington, D. C.
May 17, 2021Judgment REVERSED and case REMANDED. Kagan, J., delivered the opinion for a unanimous Court. Sotomayor, J., and Kavanaugh, J., filed concurring opinions.
Jun 18, 2021JUDGMENT ISSUED.
Recommended Citation: CIC Services, LLC v. Internal Revenue Service, SCOTUSblog, https://www.scotusblog.com/cases/cic-services-llc-v-internal-revenue-service/