Overcoming IRS Statute of Limitations Defenses: An Analysis of Informal Claims and Disaster Relief in Singh v. United States
Donnelly issued a pivotal ruling denying the government's motion to dismiss for lack of subject matter jurisdiction.
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Donnelly issued a pivotal ruling denying the government's motion to dismiss for lack of subject matter jurisdiction.
24, 2026) Tax practitioners frequently encounter situationally complex client cases where taxpayers, acting without immediate legal or tax counsel, submit informal written requests to the Internal Revenue...
When formal amended returns (Form 1040-X) are subsequently submitted past the standard statutory period under Internal Revenue Code (IRC) § 6511(a), the IRS routinely asserts a lack of subject matter...
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Donnelly issued a pivotal ruling denying the government's motion to dismiss for lack of subject matter jurisdiction. 24, 2026) Tax practitioners frequently encounter situationally complex client cases where taxpayers, acting without immediate legal or tax counsel, submit informal written requests to the Internal Revenue Service (IRS) explaining economic hardships or casualty events. When formal amended returns (Form 1040-X) are subsequently submitted past the standard statutory period under Internal Revenue Code (IRC) § 6511(a), the IRS routinely asserts a lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1), claiming sovereign immunity.
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24, 2026) Tax practitioners frequently encounter situationally complex client cases where taxpayers, acting without immediate legal or tax counsel, submit informal written requests to the Internal Revenue Service (IRS) explaining economic hardships or casualty events. When formal amended returns (Form 1040-X) are subsequently submitted past the standard statutory period under Internal Revenue Code (IRC) § 6511(a), the IRS routinely asserts a lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1), claiming sovereign immunity. 24, 2026), United States District Judge Ann M.
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