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CIC Services, LLC v. Internal Revenue Service

Docket No. Op. Below Argument Opinion Vote Author Term
19-930 6th Cir. Dec 1, 2020 May 17, 2021 9-0 Kagan OT 2020

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 Justice Kagan on May 17, 2021. Justice Sotomayor and Justice Kavanaugh filed concurring opinions.

DateProceedings and Orders (key to color coding)
10/21/2019Application (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.
10/28/2019Application (19A440) granted by Justice Sotomayor extending the time to file until January 3, 2020.
12/13/2019Application (19A440) to extend further the time from January 3, 2020 to January 17, 2020, submitted to Justice Sotomayor.
12/17/2019Application (19A440) granted by Justice Sotomayor extending the time to file until January 17, 2020.
01/17/2020Petition for a writ of certiorari filed. (Response due February 24, 2020)
02/14/2020Brief amicus curiae of American College of Tax Counsel filed.
02/18/2020Brief amicus curiae of Tax Clinic at the Legal Services Center of Harvard Law School filed.
02/19/2020Motion to extend the time to file a response from February 24, 2020 to March 25, 2020, submitted to The Clerk.
02/19/2020Brief amicus curiae of Patrick J. Smith filed.
02/20/2020Motion to extend the time to file a response is granted and the time is extended to and including March 25, 2020.
02/21/2020Brief amicus curiae of Americans for Prosperity Foundation filed.
02/24/2020Brief amicus curiae of Chamber of Commerce of the United States of America filed.
02/24/2020Brief amicus curiae of The Cato Institute filed.
02/24/2020Brief amicus curiae of Kristin E. Hickman filed.
02/24/2020Brief amici curiae of Kentucky Captive Association, Inc., et al. filed.
03/25/2020Brief of respondent Internal Revenue Service in opposition filed.
04/03/2020Reply of petitioner CIC Services, LLC filed.
04/08/2020DISTRIBUTED for Conference of 4/24/2020.
04/27/2020DISTRIBUTED for Conference of 5/1/2020.
05/04/2020Petition GRANTED.
05/18/2020Joint motion of the parties for an extension of time to file the briefs on the merits filed.
05/28/2020Joint 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.
05/28/2020Blanket Consent filed by Petitioner, CIC Services, LLC
07/06/2020Motion to dispense with printing the joint appendix filed by petitioner CIC Services, LLC.
07/14/2020Brief amicus curiae of Center for Taxpayer Rights filed.
07/15/2020Brief of petitioner CIC Services, LLC filed.
07/16/2020Brief amicus curiae of Patrick J. Smith filed.
07/22/2020Brief amicus curiae of Americans for Prosperity Foundation filed.
07/22/2020Brief amicus curiae of Chamber of Commerce of the United States of America filed.
07/22/2020Brief amicus curiae of American College of Tax Counsel filed.
07/22/2020Brief amici curiae of National Federation of Independent Business Small Business Legal Center, et al. filed.
07/22/2020Motion for leave to file amicus brief filed by Institute for Free Speech (7/31/2020).
07/22/2020Amicus brief of Institute for Free Speech not accepted for filing. (July 28, 2020 - Corrected version submitted).
07/22/2020Brief amicus curiae of Kristin E. Hickman filed.
07/22/2020Brief amici curiae of Alabama Captive Insurance Association, Inc., et al. filed.
07/22/2020Amicus brief of Partnership for Conservation not accepted for filing. (July 31, 2020 - Corrected version submitted)
07/22/2020Brief amicus curiae of National Taxpayers Union Foundation filed.
07/28/2020Motion for leave to file amicus brief out of time filed by Partnership for Conservation (7/31/2020).
08/11/2020Brief amicus curiae of Professor Bryan T. Camp filed.
08/24/2020Motion to dispense with printing the joint appendix filed by petitioner GRANTED.
09/08/2020Brief of respondent Internal Revenue Service filed.
09/11/2020Motion for leave to file amicus brief filed by Institute for Free Speech GRANTED.
09/11/2020Motion for leave to file amicus brief out of time filed by Partnership for Conservation GRANTED.
09/15/2020Brief amici curiae of Former Government Officials filed.
09/16/2020SET FOR ARGUMENT on Tuesday, December 1, 2020.
10/08/2020Record requested from the U.S.C.A. 6th Circuit.
10/08/2020Reply of petitioner CIC Services, LLC filed.
10/08/2020The record received from the U.S.C.A. 6th Circuit has been electronically filed.
10/27/2020CIRCULATED
12/01/2020Argued. For petitioner: Cameron T. Norris, Arlington, Va. For respondents: Jonathan C. Bond, Assistant to the Solicitor General, Department of Justice, Washington, D. C.
05/17/2021Judgment REVERSED and case REMANDED. Kagan, J., delivered the opinion for a unanimous Court. Sotomayor, J., and Kavanaugh, J., filed concurring opinions.
06/18/2021JUDGMENT ISSUED.