Alston & Bird Tax Blog

When Is a Deadline Not a Deadline? The Supreme Court Intends to Decide

By and

Our Federal Tax Group investigates why the U.S. Supreme Court may use a Tax Court case to decide whether a statutory deadline is set in stone or if a court can permit an untimely suit to proceed through equitable tolling.

  • The Tax Court ruled that a statutory deadline is jurisdictional; Eighth Circuit agrees
  • Taxpayer access to the Tax Court is at stake
  • The COVID-19 pandemic – and its attendant delays – has thrown the issue into the spotlight

Read the full advisory here.

About Laura Gavioli

Laura L. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an experienced first-chair trial lawyer, Laura is known for achieving practical, client-driven goals when defending against IRS inquiries.

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About George Abney

George Abney is a partner on the firm’s Tax Controversy Team, whose practice focuses on civil and criminal tax controversy matters. George has significant trial and appellate experience gained from years as a federal prosecutor with the Tax Division of the U.S. Department of Justice in Washington, D.C., and as an assistant U.S. attorney in the Northern District of Florida.

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