No. 22-1179
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
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
Petition for a writ of certiorari filed. (Response due July 6, 2023)
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
United States
Elizabeth B. Prelogar — Solicitor General, Respondent