No. 18-1133

Henry J. Langer, et ux. v. Commissioner of Internal Revenue

Lower Court: Eighth Circuit
Docketed: 2019-03-01
Status: Denied
Type: Paid
Response Waived
Tags: 8th-circuit burden-of-proof civil-procedure clear-and-convincing-evidence penalty-assessment tax-court tax-court-review tax-evasion tax-fraud tax-liability tax-penalties
Key Terms:
Environmental SocialSecurity Securities Immigration
Latest Conference: 2019-04-12
Question Presented (from Petition)

Whether Respondent has proved by clear and convincing evidence that Henry J. Langer is liable for the fraud penalty for the years 2011, 2012, and 2013?

Whether Respondent has proved by clear and convincing evidence that Patricia K. Langer is liable for the fraud penalty for the years 2011, 2012, and 2013?

Question Presented (AI Summary)

Whether the IRS has proved by clear and convincing evidence that Henry J. Langer and Patricia K. Langer are liable for fraud penalties for tax years 2011-2013

Docket Entries

2019-04-15
Petition DENIED.
2019-03-27
DISTRIBUTED for Conference of 4/12/2019.
2019-03-22
Waiver of right of respondent CIR to respond filed.
2019-02-25
Petition for a writ of certiorari filed. (Response due April 1, 2019)

Attorneys

CIR
Noel J. FranciscoSolicitor General, Respondent
Henry Langer, et al.
Henry J. Langer — Petitioner