Supreme Court of the United States · Official docket →
Joe Alfred Izen, Jr. v. Commissioner of Internal Revenue
Paid petition · United States Court of Appeals for the Fifth Circuit, No. 21-60679 · judgment June 29, 2022
Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.
Questions presented
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Whether equitable tolling may extend substantiation evidence gathering deadlines under I.R.C. § 170(f )(12).
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Whether Congress lacks the power to delegate unbridled discretion to the Commissioner to refuse to promulgate regulations which provide equitable relief from filing deadlines in appropriate cases.
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Whether in a statutory scheme conflicting provisions must be construed and applied, if possible, so that both competing purposes can be realized.
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Whether Petitioner was entitled to a hardship exemption under I.R.C. § 170(f )(11).
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Whether the Petitioner Izen was entitled to summary judgment because the Commissioner failed to present controverting evidence supporting his claim that a charitable deduction was never made and that the charitable deduction had no value.
Counsel of record
For petitioner
Joe Alfred Izen Jr.
For respondent
Elizabeth B. Prelogar
Solicitor General
Proceedings
- Apr 24 2023Petition DENIED.
- Apr 05 2023DISTRIBUTED for Conference of 4/21/2023.
- Mar 28 2023Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
- Feb 23 2023Petition for a writ of certiorari filed. (Response due March 29, 2023)
- Dec 14 2022Application (22A520) granted by Justice Alito extending the time to file until February 27, 2023.
- Dec 09 2022Application (22A520) to extend the time to file a petition for a writ of certiorari from December 29, 2022 to February 27, 2023, submitted to Justice Alito.