Supreme Court of the United States · Official docket →
Seaview Trading, LLC, AGK Investments, LLC, Tax Matters Partner v. Commissioner of Internal Revenue
Paid petition · United States Court of Appeals for the Ninth Circuit, No. 20-72416 · judgment March 10, 2023
Certiorari denied · January 8, 2024
Pre-decision estimate: 13% cert probability (95% interval 9%–18%)
Before the decision, about 3× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a Ninth Circuit decision below, and a dissent in the court below (flagged in the petition).
Question presented
Whether the word “file” in 26 U.S.C. § 6229 (2000) and as used throughout the Tax Code carries its ordinary meaning for delinquent tax returns when no regulation specifies how to file delinquent returns. (I)
Counsel of record
For petitioner
Lisa S. Blatt
Williams & Connolly LLP
For respondent
Elizabeth B. Prelogar
Solicitor General
Proceedings
- Jan 08 2024Petition DENIED.
- Nov 29 2023DISTRIBUTED for Conference of 1/5/2024.
- Nov 29 2023Reply of petitioner Seaview Trading, LLC, AGK Investments, LLC, Tax Matters Partner filed. (Distributed)
- Nov 15 2023Brief of respondent Commissioner of Internal Revenue in opposition filed.
- Oct 11 2023Motion to extend the time to file a response is granted and the time is extended to and including November 15, 2023.
- Oct 10 2023Motion to extend the time to file a response from October 16, 2023 to November 15, 2023, submitted to The Clerk.
- Sep 14 2023Response Requested. (Due October 16, 2023)
- Sep 13 2023DISTRIBUTED for Conference of 10/6/2023.
- Sep 08 2023Brief amicus curiae of National Taxpayers Union Foundation filed.
- Sep 08 2023Brief amicus curiae of Center for Taxpayer Rights filed.
- Sep 05 2023Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
- Aug 07 2023Petition for a writ of certiorari filed. (Response due September 8, 2023)
- May 10 2023Application (22A982) granted by Justice Kagan extending the time to file until August 7, 2023.
- May 05 2023Application (22A982) to extend the time to file a petition for a writ of certiorari from June 8, 2023 to August 7, 2023, submitted to Justice Kagan.