United States Seventh Circuit

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Lantz v. Comm'r of Internal Revenue, 09-3345

Tax Court's judgment invalidating the two-year deadline that the Treasury has imposed on claims under section 6015(f), and thus reversing the IRS's denial of a taxpayer's application for innocent-spouse relief, is reversed as the fact that Congress designated a deadline in two provisions of the same statute and not in a third is not a compelling argument that Congress meant to preclude the Treasury Department from imposing a deadline applicable to cases governed by that third provision.

Appellate Information

  • Argued 04/09/2010
  • Decided 06/08/2010
  • Published 06/08/2010


  • POSNER, Circuit Judge., Before POSNER, FLAUM, and WILLIAMS, Circuit Judges.


  • United States Seventh Circuit


  • For Appellant:
  • A. Lavar Taylor, Attorney, Santa Ana, CA, for Center for the Fair Administration of Taxes.

  • For Appellees:
  • Paul M. Kohlhoff, Attorney, Valparaiso University Law Clinic, Valparaiso, IN, for Petitioner-Appellee., Steven W. Parks, Attorney, Teresa E. McLaughlin, Attorney, Department of Justice, Washington, DC, for Respondent-Appellant.