Baccei v. United States

How courts have described this case

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

• holding that we do not generally consider arguments raised for the first time on appeal
• holding that we do not generally consider arguments raised for the first time on appeal
• holding that “even if the IRS were negligent in failing to notify [plaintiff], negligence alone will not support a claim of equitable estoppel against the government”
• “Absent exceptional circumstances, we generally will not consider arguments raised for the first time on appeal, although we have discretion to do so.”
• “[W]e will not reframe an appeal to review what would be in effect a different case than the one decided by the district court.”
• “Absent exceptional circumstances, we generally will not consider arguments raised for the first time on appeal.”

Source: CourtListener parenthetical corpus (CC0).