1. “Whether the Supreme Court erred in their interpretation of the Internal Revenue Code in United States v. Brockamp, 519 U.S. 347 (1997) by disallowing equitable tolling in all circumstances because they may not have been aware of the tension between two United States Codes (26 U.S.C. §651l(a) and 10 U.S.C. §1174(h)(l)) resulting in an adverse financial impact on a large group of taxpayers.” 2. “Whether the Brockamp decision will be overturned to allow equitable tolling for taxpayers caught between two United States Codes because of Brockamp’s precedent on lower court rulings.” 3. “Whether United States military retirees can obtain a fair outcome to recover taxes paid on funds that were later returned to the federal government.”
