No. 22-1179

Sabena Puri v. United States

Lower Court: Ninth Circuit
Docketed: 2023-06-06
Status: Denied
Type: Paid
Response Waived
Tags: abuse-of-process foreign-government-inquiry good-faith irs-summons judicial-process judicial-review powell-framework tax-treaty treaty-request united-states-v-powell united-states-v-stuart
Key Terms:
Environmental SocialSecurity Securities Immigration
Latest Conference: 2023-09-26
Question Presented (from Petition)

Is a foreign government's abusive or bad faith purpose ever relevant to the enforcement of an IRS summons issued pursuant to a treaty request?

Question Presented (AI Summary)

Is a foreign government's abusive or bad faith purpose ever relevant to the enforcement of an IRS summons issued pursuant to a treaty request?

Docket Entries

2023-10-02
Petition DENIED.
2023-06-28
DISTRIBUTED for Conference of 9/26/2023.
2023-06-20
Waiver of right of respondent United States to respond filed.
2023-06-02
2023-03-17
Application (22A826) granted by Justice Kagan extending the time to file until June 3, 2023.
2023-03-15
Application (22A826) to extend the time to file a petition for a writ of certiorari from April 4, 2023 to June 3, 2023, submitted to Justice Kagan.

Attorneys

Sabena Puri
Derick Roberson VollrathMarcus Neiman Rashbaum and Pineiro LLP, Petitioner
United States
Elizabeth B. PrelogarSolicitor General, Respondent