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.
- 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.