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Justice Brett Kavanaugh said: “[T]he fact that a NorthDakotaLawFirm, Boechler, P.C., The statute does not say that as to the 30-day deadline. Multiple justices commented that the government’s case could be undermined by the many plausible statutory interpretations of a 30-day deadline.
a NorthDakotalawfirm, of intent to levy on Boechler’s property to satisfy a tax penalty. It held instead that the statute is not jurisdictional, and that equitable tolling is an available argument in Tax Court. The statute provides for jurisdiction over “such matter,” but does not say what “such matter” is.
It will also add to the court’s precedent on the interaction between the law of equity and the technicalities of federal statutes. Partly because of the circuit split and partly because of the statute’s lack of clarity, this could be a close case. Circuit agreed with the firm’s approach in 2019 in Myers v.
The court also noted that states and localities “expressly maintain control over the local distribution of natural gas under related federal statutes” such as the Natural Gas Act. The court declined to exercise supplemental jurisdiction over the plaintiff’s state law claims and dismissed them without prejudice. NorthDakota v.
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