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NAUFLETT v. C.I.R.

No. 17-1986.

892 F.3d 649 (2018)

Shari Renee NAUFLETT, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided: June 14, 2018.

Attorney(s) appearing for the Case

ARGUED: Allison Bray , HARVARD LAW SCHOOL, Jamaica Plain, Massachusetts; Carlton Malben Smith , New York, New York, for Appellant. Richard Caldarone , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. ON BRIEF: T. Keith Fogg , Director, Harvard Federal Tax Clinic, HARVARD LAW SCHOOL, Jamaica Plain, Massachusetts, for Appellant. David A. Hubbert , Acting Assistant Attorney General, Francesca Ugolini , Tax Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Affirmed by published opinion. Judge Agee wrote the opinion, in which Judge Traxler and Judge Wynn joined.

Shari Renee Nauflett appeals from the dismissal by the United States Tax Court of her petition for relief from unpaid tax liability based on spousal innocence. Nauflett filed her petition one week after the expiration of the 90-day filing requirement in section 6015(e)(1)(A)(ii) of the Internal Revenue Code. The Tax Court held...

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