Lantz v. Commissioner

How courts have described this case

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

• rejecting argument that equitable relief under § 6015(f) carries with it a ten-year limitations period, as opposed to a two-year period
• noting “fact that Congress designated a deadline in two provisions of the same statute and not in third is not a compelling argument that Congress meant to preclude the [Secretary] from imposing a deadline applicable to cases governed by that third provision”
• “[A]ny statute of limitations will cut off some, and often a great many, meritorious claims.”
• “‘[E]quity aids the vigilant, not those who sleep on their rights.’”
• Commissioner could impose fixed deadline on section 6015(f) equitable relief provision
• “that Congress designated a deadline in two provisions of the same statute and not in a third is not a compelling argument that Congress meant to preclude the Treasury Department from imposing a deadline applicable to cases governed by that third provision”

Source: CourtListener parenthetical corpus (CC0).