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Phyllis Carr v. Internal Revenue Service, et al.

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 21-17100 · judgment January 25, 2023

Certiorari denied · November 13, 2023
Pre-decision estimate: 0% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. Does the closing of an examination/audit following complaints of violation of the Taxpayer Bill of Right against the IRS auditors during the audit allow IRS to pay a refund pursuant to the exami­ nation as it did in this case?

  2. Can the Taxpayer Advocate Service help the tax­ payer obtain their refund in helping the taxpayer resolve complaints against IRS arising from the examination?

Counsel of record

For petitioner
Phyllis E. Carr

For respondent
Elizabeth B. Prelogar
Solicitor General

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Nov 13 2023
    Petition DENIED.
  2. Nov 06 2023
    Supplemental brief of petitioner Phyllis Carr filed. (Distributed)
    Main DocumentProof of ServiceCertificate of Word Count
  3. Oct 24 2023
    DISTRIBUTED for Conference of 11/9/2023.
  4. Oct 18 2023
    Waiver of right of respondent IRS, et al. to respond filed.
    Main Document
  5. Aug 03 2023
    Petition for a writ of certiorari filed. (Response due November 13, 2023)
    PetitionAppendixCertificate of Word CountProof of Service