No. 19-57
Donald Dewees v. United States
Response Waived
Tags: administrative-procedure due-process eighth-amendment equal-protection excessive-fines international-tax international-taxation streamlined-filing-compliance-procedures tax-assessment tax-collection tax-compliance tax-convention tax-penalties
Key Terms:
AdministrativeLaw DueProcess FifthAmendment Punishment JusticiabilityDoctri
AdministrativeLaw DueProcess FifthAmendment Punishment JusticiabilityDoctri
Latest Conference:
2019-10-01
Question Presented (from Petition)
1. Did the lack of a meaningful review of the assessment and collection of a tax under the Convention violate Dewees' right to due process?
2. Did the IRS' arbitrary refusal to allow Dewees' to enter the SFCP violate his equal protection rights, where other non-resident taxpayers allowed into the program avoid late-filing penalties?
3. Were the civil fines assessed and collected against Dewees for late filings of Form 5471 excessive under the Eighth Amendment, especially where the IRS acknowledged Dewees owed no tax?
Question Presented (AI Summary)
Did the lack of a meaningful review of the assessment and collection of a tax under the Convention violate Dewees' right to due-process?
Docket Entries
2019-10-07
Petition DENIED.
2019-07-31
DISTRIBUTED for Conference of 10/1/2019.
2019-07-26
Waiver of right of respondent United States to respond filed.
2019-07-05
Petition for a writ of certiorari filed. (Response due August 8, 2019)
Attorneys
Donald Dewees
Mark Allan Feigenbaum — Attorney At Law, Petitioner
United States
Noel J. Francisco — Solicitor General, Respondent