Attorney(s) appearing for the Case
Matthew D. Carlson (argued) and Douglas L. Youmans , Wagner Kirkman Blaine Klomparens & Youmans, Mather, California, for Petitioners-Appellants.
Paul Andrew Allulis (argued), Francesca Ugolini , and Patrick J. Urda , Attorneys; Richard E. Zuckerman , Principal Deputy Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Respondent-Appellee. Carlton M. Smith , New York, New York; Professor T. Keith Fogg , Director, Federal Tax Clinic of the Legal Services Center of Harvard Law School, Jamaica Plain, Massachusetts; for Amicus Curiae Federal Tax Clinic of the Legal Services Center of Harvard Law School.
Before: Jay S. Bybee, N. Randy Smith, and Daniel P. Collins, Circuit Judges.
COLLINS, Circuit Judge.
This unhappy case presents a cautionary tale about the need for lawyers to ensure that they have done exactly what is statutorily required to invoke a court's jurisdiction. The unusual Internal Revenue Code ("I.R.C.") provision at issue here allows taxpayers to benefit from a "mailbox" rule—i.e...
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