Supreme Court Requests Government Response to Whirlpool’s Petition

By on August 19, 2022

We previously discussed the petition for writ of certiorari that was filed in the Supreme Court of the United States by Whirlpool Financial Corporation & Consolidated Subsidiaries and Whirlpool International Holdings S.a.r.l. & Consolidated Subsidiaries (collectively, Whirlpool); the amici briefs filed by The National Association of Manufacturers, the Silicon Valley Tax Directors Group, and three of the “Big 4” accounting firms in support of Whirlpool’s petition; and how the case is now up for consideration at the Supreme Court’s upcoming conference on September 28, 2022. We also noted how the US government waived its right to file a response to Whirlpool’s petition.

In the latest update regarding Whirlpool’s petition, in a minute entry on the docket sheet, the Supreme Court has requested that the government provide a response by September 19, 2022. That response will then be considered by the Supreme Court at its September 28 conference, absent a relisting of the matter for a later conference. We will continue to monitor further developments in Whirlpool’s case and provide any further updates as they are made available.

Andrew R. Roberson
Andrew (Andy) R. Roberson focuses his practice on tax controversy and litigation matters. He represents clients before the Internal Revenue Service (IRS) Examination Division and Appeals Office and has been involved in over 75 matters at all levels of the federal court system, including the US Tax Court and Federal District Courts, several US Courts of Appeal and the Supreme Court. Andy has experience settling tax disputes through alternative dispute resolution procedures, including Fast Track Settlement and Post-Appeals Mediation, and in representing clients in Compliance Assurance Process (CAP) audits. In addition to representing corporations and partnerships in tax disputes, he also represents high net-worth individuals and assists taxpayers needing to make voluntary disclosures. Read Andy Roberson's full bio.

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