Diligence, Law Firms and North Dakota

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

SCOTUSBlog

JANUARY 11, 2022

The dispute arose after the Internal Revenue Service assessed a $19,250 penalty and issued a notice of intent to levy to a small North Dakota law firm for failing to file employee tax withholding forms. The firm points out that CDP proceedings are directed disproportionately at unsophisticated taxpayers.

Statute

Statute Law Firm Law Firms Government

Equitable tolling in a corner of the Internal Revenue Code

SCOTUSBlog

APRIL 25, 2022

a North Dakota law firm, of intent to levy on Boechler’s property to satisfy a tax penalty. According to the brief, Castillo did not know (despite diligent efforts to find out) that the IRS was incorrectly assessing her for tax on the earnings of a business she had long since sold. The case, Boechler v.

Statute

Statute Court Diligence Government

Paralegal Brief

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

Equitable tolling in a corner of the Internal Revenue Code

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