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Equitable tolling in a corner of the Internal Revenue Code

SCOTUSBlog

a North Dakota law firm, of intent to levy on Boechler’s property to satisfy a tax penalty. It held instead that the statute is not jurisdictional, and that equitable tolling is an available argument in Tax Court. The statute provides for jurisdiction over “such matter,” but does not say what “such matter” is.

Statute 78
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A tax deadline missed by one day leads to a showdown over equity, jurisdiction – and grammar

SCOTUSBlog

It will also add to the court’s precedent on the interaction between the law of equity and the technicalities of federal statutes. Partly because of the circuit split and partly because of the statute’s lack of clarity, this could be a close case. Circuit agreed with the firm’s approach in 2019 in Myers v.

Statute 82