News & Analysis as of

Equitable Tolling

Rivkin Radler LLP

Will Congress Extend the Statutory Period For Filing a Petition With the U.S. Tax Court?

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Last week, an amicus brief was filed with the First Circuit Court of Appeals in support of a taxpayer’s challenge to the U.S. Tax Court’s dismissal of the taxpayer’s petition for lack of jurisdiction. The Tax Court determined...more

Rivkin Radler LLP

Responding Timely to A “90-Day Letter” – Is It Jurisdictional?

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In the fictional world of John Wicks, the High Table enforces a strict code of conduct without which the lives of its inhabitants would mimic life in a Hobbesian state of nature. However, as dangerous and as rule-bound as...more

Orrick, Herrington & Sutcliffe LLP

Mortgage lender files writ of cert. with SCOTUS

On August 25, the U.S. Supreme Court received a writ of certiorari from a mortgage lender (the petitioner) challenging a decision by the U.S. Court of Appeals for the 2nd Circuit upholding a jury verdict finding the...more

McDermott Will & Schulte

On repeat: Separate accrual rule doesn’t apply to continuing harm from infringing act

The US Court of Appeals for the First Circuit affirmed a district court’s dismissal of a copyright lawsuit as time barred, finding that the separate accrual rule does not apply to continuing harm from a single infringing act....more

Fox Rothschild LLP

CICA Stay Preserved: COFC Rules in Favor of Protester, Applies Equitable Tolling

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The Competition in Contracting Act (CICA) of 1984 establishes a procedure that effectively pauses performance of a federal contract award during a bid protest. If a disappointed bidder files a protest with the Government...more

McGlinchey Stafford

Court Finds TILA Statute of Limitation is Not Equitably Tolled

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On March 31, 2025, the Western District of New York dismissed a pro se plaintiff’s Truth-in-Lending Act (TILA) claim as being time-barred. In Marion v. Transitowne Jeep Chrysler Dodge Ram Williamsville, the Plaintiff...more

Robinson Bradshaw

When Does American Pipe Tolling End?

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Under the American Pipe doctrine, the commencement of a class action tolls the statute of limitations for absent class members. American Pipe & Construction Co. v. Utah, 414 U.S. 538, 554 (1974). The intent of this rule is to...more

Miller Canfield

Why Shouldn’t Equitable Tolling Apply to the Federal Tax Refund Look-Back Period?

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In Libitzky v. United States, the United States Court of Appeals for the Ninth Circuit affirmed disallowance of a $700,000 federal income tax refund claim. The court said that this was an “unfortunate” case, but they were...more

Marshall Dennehey

Pennsylvania Superior Court Affirmed Judgment on the Pleadings in Legal Malpractice Case Based Upon Statute of Limitations

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The plaintiffs alleged the court erred in not allowing them to amend their pleadings to clarify facts regarding equitable tolling and erred in not recognizing that issues of fact existed. The trial court found, and the...more

Miller Canfield

Can a Tax Court Filing Deadline be Equitably Tolled?

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All is not necessarily lost if a taxpayer files a petition after the filing deadline in United States Tax Court to contest a federal tax deficiency. A recent case ruled that the filing deadline may be suspended in appropriate...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Massachusetts SJC Holds That COVID-19–Related Tolling Does Not Extend Time to File a Complaint at the MCAD

On July 11, 2023, the Massachusetts Supreme Judicial Court (SJC) declined to extend its early COVID-19 emergency orders to the time limits established for filing a complaint with the Massachusetts Commission Against...more

Carlton Fields

11th Circuit: District Courts May Equitably Toll FAA 3-Month Deadline to Challenge Arbitration Awards

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In a case of first impression, the Eleventh Circuit Court of Appeals, on June 21, 2023, in NuVasive Inc. v. Absolute Medical LLC, held that the three-month time limit for challenging arbitration awards under the Federal...more

Carlton Fields

Medical Incapacity Does Not Toll Life Insurance Conversion Period

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A plan administrator did not abuse its discretion in concluding that a former employee’s surviving spouse was not entitled to life insurance benefits under an employee benefit plan. In Hayes v. Prudential Insurance Company of...more

Morrison & Foerster LLP - Federal Circuitry

Last Week In The Federal Circuit (January 23 – January 27): Furnishing Statutory Meaning

The Supreme Court recently issued its first decision of the Term in Arellano v. McDonough, affirming the Federal Circuit and holding that a statutory provision governing the effective date of a veterans’ benefits application...more

Epstein Becker & Green

The First Rulings of the New Term – Dismissing Attorney-Client Privilege Case, Denying Equitable Tolling in Veteran’s Benefits...

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While many commentators were wondering when the Supreme Court would start issuing opinions, the backlog of argued cases now being substantial, today is their day. ...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Arellano v. McDonoughhts

On January 23, 2023, the U.S. Supreme Court decided Arellano v. McDonough, affirming the Federal Circuit, and holding that equitable tolling did not apply to a statutory rule that the effective date for an award of veteran’s...more

Dorsey & Whitney LLP

The Supreme Court Update - January 23, 2023

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Today, the Supreme Court of the United States issued its first signed opinion of the October 2022 term and dismissed one case: Arellano v. McDonough, No. 21-432: The case concerns the question of whether equitable...more

Freeman Law

Tax Court in Brief | Hallmark v. Comm’r | No Equitable Tolling of 90-Day Deadline to Petition Notice of Deficiency

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

McDermott Will & Schulte

Tax Court Holds That Deficiency Petition 90-Day Time Limit Is Jurisdictional

Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable tolling (Boechler, P.C. v....more

McGuireWoods LLP

Eleventh Circuit Concludes that Foreign Country’s Equitable Tolling Standards Can Apply in Federal Class Action

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In a recent case addressing the novel issue of whether foreign law trumped United States law for purposes of class action tolling, the U.S. Court of Appeals for the Eleventh Circuit concluded that Colombian law on equitable...more

Miller Canfield

Procedural Actions Following the Supreme Court Remand in Boechler

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Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more

McDermott Will & Schulte

Late CDP Petitions May Still Be Entitled to Tax Court Review

In a unanimous decision in Boechler, P.C. v. Commissioner issued on April 21, 2022, the Supreme Court of the United States reversed the US Court of Appeals for the Eighth Circuit’s ruling (which affirmed the US Tax Court) and...more

Dorsey & Whitney LLP

The Supreme Court - April 21, 2022

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Boechler, P.C. v. Commissioner of Internal Revenue, No. 20-1472: This case involves the application of “equitable tolling” in tax “collection due process” cases. This case arose after the IRS sustained a proposed levy on the...more

Morrison & Foerster LLP - Federal Circuitry

A Cert Grant On Veterans' Benefits And Equitable Tolling

As Federal Circuitry readers know, the Supreme Court in recent years has granted review in many patent cases from the Federal Circuit—like last Term’s big decision in Arthrex. But the Supreme Court also takes up cases from...more

Dorsey & Whitney LLP

The Supreme Court - February 22, 2022

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Adolfo Arellano v. Secretary of Veterans Affairs, No. 21-432: This case concerns whether equitable tolling may extend the deadline for veterans to submit an application for disability benefits under 38 U.S.C. § 5110(b)(1)...more

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