No. 18-1425

Naren Chaganti v. Commissioner of Internal Revenue

Lower Court: Eighth Circuit
Docketed: 2019-05-14
Status: Denied
Type: Paid
Response Waived
Tags: binding court-order hearsay hearsay-exception internal-revenue-code internal-revenue-code-162(f) litigation-sanctions parties standing stipulations tax-court-rule tax-court-rule-91-a-e tax-court-stipulations tax-cuts-and-jobs-act tax-cuts-and-jobs-act-2017
Latest Conference: 2019-06-13
Question Presented (from Petition)

1) Whether stipulations filed under Tax Court Rule 91(a) & (e) are binding on the parties and the Tax Court.

2) Whether statements in a court order in one case may be used for their truth in a different case over a hearsay objection.

3) Whether litigation sanctions ordered by a district court and paid to an opposing party are "fines" or "penalties" "paid to a government" under Internal Revenue Code § 162(f) (2006), in light of the change to the code section enacted in the Tax Cuts & Jobs Act of 2017.

Question Presented (AI Summary)

Whether stipulations filed under Tax Court Rule 91(a) & (e) are binding on the parties and the Tax Court

Docket Entries

2019-06-17
Petition DENIED.
2019-05-28
DISTRIBUTED for Conference of 6/13/2019.
2019-05-22
Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
2019-05-10
Petition for a writ of certiorari filed. (Response due June 13, 2019)

Attorneys

Commissioner of Internal Revenue
Noel J. FranciscoSolicitor General, Respondent
Naren Chaganti
Naren ChagantiLaw Offices of Naren Chaganti, Petitioner