Legal Opinion
Doe 1 v. KPMG LLP
Court of Appeals for the Fifth Circuit
Decided February 10, 2005No. 04-10470PublishedCited by 27 opinions
1Opinion of the Court
EDITH H. JONES, Circuit Judge:
This appeal challenges the district court’s jurisdiction to apply equitable tolling to the statute of limitations of Internal Revenue Code § 6501, 26 U.S.C. § 6501 (hereafter “I.R.C.”). Because we conclude that equitable tolling may not be used to extend this provision’s three-year period, we REVERSE the district court.
Background
In September 2000, the Internal Revenue Service (“IRS”) published Notice 2000-44, 1 which requires organizers and promoters of certain tax shelters to maintain lists of participants and to provide those lists to the IRS upon request. The…
2Cases cited13 opinions
- Library of Congress v. ShawSupreme Court of the United States · 1986
- Soriano v. United StatesSupreme Court of the United States · 1957
- United States v. BrockampSupreme Court of the United States · 1997
- Commissioner v. SchleierSupreme Court of the United States · 1995
- Young v. United StatesSupreme Court of the United States · 2002
8 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Elam v. Kansas City Southern Railway Co.Court of Appeals for the Fifth Circuit · 2011
- Minehan v. United StatesUnited States Court of Federal Claims · 2007
- United States v. JacksonCourt of Appeals for the Fifth Circuit · 2005
- Modica v. TaylorCourt of Appeals for the Fifth Circuit · 2006
- Equal Employment Opportunity Commission v. E.I. Du Pont De Nemours & Co.Court of Appeals for the Fifth Circuit · 2007
22 more not listed; retrieve them via the Exa API.