Seventh Circuit to Consider Petition for Rehearing in Beard
On March 7, the taxpayer filed a petition for rehearing en banc (attached below) with the Seventh Circuit in Beard, emphasizing that both the Fifth and Fourth Circuits had explicitly disagreed with...
View ArticleNew Government Filings Try to Unify Courts of Appeals Behind the Six-Year...
As we have reported extensively (e.g. here and here), the courts of appeals appear to be hopelessly split on the “Intermountain” issue of whether a six-year statute of limitations applies to...
View ArticleD.C. Circuit Leans Toward Government at Intermountain Oral Argument
On April 5, the D.C. Circuit (Judges Sentelle, Randolph, and Tatel) heard oral argument in Intermountain and its companion case, UTAM. The court’s questions generally indicated that the most likely...
View ArticleSeventh Circuit Denies Rehearing in Beard
The Seventh Circuit today denied the taxpayer’s rehearing petition in Beard. Coupled with the Fourth Circuit’s denial of rehearing in Home Concrete a few days ago, this action removes the faint...
View ArticleTenth Circuit Sides With Government on Intermountain Issue
The Tenth Circuit, after a long period of deliberation, has reversed the Tax Court in Salman Ranch. (Opinion linked here.) This now makes the score 3-2 in favor of the government in the series of...
View ArticleBeard Becomes First Intermountain Case to Reach the Supreme Court
We have been noting for the past few months that the Intermountain issue would be heading to the Supreme Court soon, with the government’s petition in the Home Concrete case due on July 5. The...
View ArticleGovernment Acquiesces in Beard Petition for Certiorari
The government has now filed its response to the taxpayer’s petition for certiorari in Beard, the first of the Intermountain cases to reach the Supreme Court. As expected, the government filed an...
View ArticleUpdate on Intermountain Cases
Although our blog coverage might reasonably be accused of hibernating over the summer, court calendars inexorably marched on, and there were several developments in the various Intermountain cases. If...
View ArticleSupreme Court Agrees to Hear Home Concrete Case to Address Six-Year Statute...
The Court this morning granted certiorari in the Home Concrete case from the Fourth Circuit, thus paving the way for a definitive, nationwide resolution of the issues presented in the Intermountain...
View ArticleHome Concrete Decision Leaves Administrative Law Questions Unsettled While...
[A shorter version of this blog post appears on SCOTUSblog.] The Supreme Court last week ruled 5-4 in favor of the taxpayer in Home Concrete, thus putting an end to the long-running saga of the...
View ArticleSeventh Circuit to Consider Petition for Rehearing in Beard
On March 7, the taxpayer filed a petition for rehearing en banc (attached below) with the Seventh Circuit in Beard, emphasizing that both the Fifth and Fourth Circuits had explicitly disagreed with...
View ArticleNew Government Filings Try to Unify Courts of Appeals Behind the Six-Year...
As we have reported extensively (e.g. here and here), the courts of appeals appear to be hopelessly split on the “Intermountain” issue of whether a six-year statute of limitations applies to...
View ArticleD.C. Circuit Leans Toward Government at Intermountain Oral Argument
On April 5, the D.C. Circuit (Judges Sentelle, Randolph, and Tatel) heard oral argument in Intermountain and its companion case, UTAM. The court’s questions generally indicated that the most likely...
View ArticleSeventh Circuit Denies Rehearing in Beard
The Seventh Circuit today denied the taxpayer’s rehearing petition in Beard. Coupled with the Fourth Circuit’s denial of rehearing in Home Concrete a few days ago, this action removes the faint...
View ArticleTenth Circuit Sides With Government on Intermountain Issue
The Tenth Circuit, after a long period of deliberation, has reversed the Tax Court in Salman Ranch. (Opinion linked here.) This now makes the score 3-2 in favor of the government in the series of...
View ArticleBeard Becomes First Intermountain Case to Reach the Supreme Court
We have been noting for the past few months that the Intermountain issue would be heading to the Supreme Court soon, with the government’s petition in the Home Concrete case due on July 5. The...
View ArticleGovernment Acquiesces in Beard Petition for Certiorari
The government has now filed its response to the taxpayer’s petition for certiorari in Beard, the first of the Intermountain cases to reach the Supreme Court. As expected, the government filed an...
View ArticleUpdate on Intermountain Cases
Although our blog coverage might reasonably be accused of hibernating over the summer, court calendars inexorably marched on, and there were several developments in the various Intermountain cases. If...
View ArticleSupreme Court Agrees to Hear Home Concrete Case to Address Six-Year Statute...
The Court this morning granted certiorari in the Home Concrete case from the Fourth Circuit, thus paving the way for a definitive, nationwide resolution of the issues presented in the Intermountain...
View ArticleHome Concrete Decision Leaves Administrative Law Questions Unsettled While...
[A shorter version of this blog post appears on SCOTUSblog.] The Supreme Court last week ruled 5-4 in favor of the taxpayer in Home Concrete, thus putting an end to the long-running saga of the...
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