1. Home
  2. Browse Decisions
  3. F.3d
  4. 398 F.3d
  5. 398 F.3d 686 (2005)
 

DOE v. KPMG, LLP

No. 04-10470.

398 F.3d 686 (2005)

John DOE 1 and John Doe 2, Plaintiff-Appellants, v. KPMG, LLP, Defendant-Appellee, United States of America, Intervenor Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

January 26, 2005.

Attorney(s) appearing for the Case

Robert H. Albaral (argued), Brian J. Hurst, Maricela Moore Siewczynski, Jay Forrest Utley, Baker & McKenzie, Dallas, TX, Thomas V.M. Linguanti, Gregory S. Lynam, Baker & McKenzie, Chicago, IL, for Plaintiffs-Appellants.

Kevin M. Dinan, King & Spalding, Washington, DC, Timothy W. Mountz, Baker Botts, Dallas, TX, for Defendant-Appellee.

Ellen Page DelSole, Frank P. Cihlar, Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Tax Div. App. Section, Washington, DC, for U.S.

Before GARWOOD, JONES and PRADO, Circuit Judges.

EDITH H. JONES, Circuit Judge:

This appeal challenges the district court's jurisdiction to apply equitable tolling to the statute of limitations of Internal Revenue Code § 6501, 26 U.S.C. § 6501 (hereafter "I.R.C."). Because we conclude that equitable tolling may not be used to extend this provision's three-year period, we REVERSE the district court.

Background

In September 2000, the Internal Revenue Service ("IRS") published Notice...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases