Legal Opinion
Shari Nauflett v. Commissioner of IRS
Court of Appeals for the Fourth Circuit
Decided June 14, 2018No. 17-1986PublishedCited by 12 opinions
1Opinion of the Court
AGEE, Circuit Judge:
Shari Renee Nauflett appeals from the dismissal by the United States Tax Court of her petition for relief from unpaid tax liability based on spousal innocence. Nauflett filed her petition one week after the expiration of the 90-day filing requirement in section 6015(e)(1)(A)(ii) of the Internal Revenue Code. The Tax Court held that the 90-day filing requirement is jurisdictional and thus cannot be excused for any reason. Nauflett argues that the deadline is instead a claim-processing rule subject to equitable tolling, and she alleges that she is entitled to have the…
2Cases cited11 opinions
- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- King v. BurwellSupreme Court of the United States · 2015
- Sebelius v. Auburn Regional Medical CenterSupreme Court of the United States · 2013
- United States v. WoodsSupreme Court of the United States · 2013
- United States v. Kwai Fun WongSupreme Court of the United States · 2015
6 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Mary Edmondson v. Eagle National BankCourt of Appeals for the Fourth Circuit · 2019
- Myers v. Comm'r of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2019
- Robert Zachariasiewicz, Jr. v. DOJCourt of Appeals for the Fourth Circuit · 2022
- Brian McLane v. IRSCourt of Appeals for the Fourth Circuit · 2022
- Brian McLane v. IRSCourt of Appeals for the Fourth Circuit · 2022
7 more not listed; retrieve them via the Exa API.