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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.

DateProceedings and Orders (key to color coding)
04/16/2021Petition for a writ of certiorari filed. (Response due May 21, 2021)
05/12/2021Motion to extend the time to file a response from May 21, 2021 to June 21, 2021, submitted to The Clerk.
05/13/2021Motion to extend the time to file a response is granted and the time is extended to and including June 21, 2021.
05/18/2021Brief amicus curiae of The Center for Taxpayer Rights filed.
05/21/2021Brief amici curiae of Federal Tax Clinic at Charles Widger School of Law et al. filed.
06/11/2021Motion to extend the time to file a response from June 21, 2021 to July 22, 2021, submitted to The Clerk.
06/14/2021Motion to extend the time to file a response is granted and the time is further extended to and including July 22, 2021.
07/22/2021Brief of respondent Commissioner of Internal Revenue in opposition filed.
08/10/2021Reply of petitioner Boechler, P.C. filed. (Distributed)
08/11/2021DISTRIBUTED for Conference of 9/27/2021.
09/30/2021Petition GRANTED.
11/15/2021Joint appendix filed. (Statement of costs filed)
11/15/2021Brief of petitioner Boechler, P.C. filed.
11/17/2021ARGUMENT SET FOR Wednesday, January 12, 2022.
11/17/2021Record requested from the U.S.C.A. 8th Circuit.
11/22/2021Brief amici curiae of National Taxpayers Union Foundation, et al., filed.
11/22/2021Brief amici curiae of Federal Tax Clinics, Legal Aid Groups, and Tax Professors filed.
11/22/2021Brief amici curiae of The Center for Taxpayer Rights, et al. filed.
11/22/2021Amicus brief of A. Lavar Taylor not accepted for filing. (Corrected version submitted - December 01, 2021).
11/22/2021Brief amicus curiae of A. Lavar Taylor filed.
12/14/2021CIRCULATED
12/15/2021Brief of respondent Commissioner of Internal Revenue filed. (Distributed)
12/30/2021Reply of petitioner Boechler, P.C. filed. (Distributed)
01/10/2022Letter from Solicitor General regarding statistics in brief on the merits filed. (Distributed)
01/10/2022Restricted documents received from the U.S.C.A. has been electronically filed.
01/11/2022Record received from the U.S.C.A. 8th Circuit. 1 - Box
01/12/2022Argued. For petitioner: Melissa Arbus Sherry, Washington, D. C. For respondent: Jonathan C. Bond, Assistant to the Solicitor General, Department of Justice, Washington, D. C.
04/21/2022Judgment REVERSED and case REMANDED. Barrett, J., delivered the opinion for a unanimous Court.
05/23/2022Judgment Issued
01/11/2023Record returned to the U.S.C.A. 8th Circuit. 1 - Box.