Abston v. Commissioner

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• collecting cases in which appeals were dismissed as 18 time-barred where taxpayer’s administrative claim of financial disability was not supported by a 19 physician’s statement that complied with Rev. Proc. 99-21
• “[t]he limited waiver of sovereign immunity in § 6511(h) does not grant district courts power to decide de novo that a taxpayer was financially disabled.”
• “The limited waiver of sovereign immunity in § 6511(h) does not grant district courts power to decide de novo that a taxpayer was financially disabled.”
• so stating and noting Treasury Regulations establishing purposes of Revenue Procedures

Source: CourtListener parenthetical corpus (CC0).