The US Supreme Court should review a ruling that Seaview Trading LLC hadn’t filed its late return despite following IRS advice to submit the return directly to agency employees rather than the designated service center, the California-based company said.
The ruling by the en banc US Court of Appeals for the Ninth Circuit, which left Seaview facing the IRS’s $35.5 million tax return adjustment, “pulled the rug out from under the countless taxpayers who heed IRS instructions and give late returns to IRS agents who request those returns,” Seaview said in its Aug. 7 petition, docketed at the high ...