No. 22-335
Richard Collins v. United States
Response Waived
Tags: bank-secrecy-act due-process fbar-penalty internal-revenue-service irs proportionality tax-reporting treasury-department willful-failure
Latest Conference:
2022-12-02
Question Presented (from Petition)
Whether the Government overreached by imposing any penalty on a taxpayer who owed no additional income tax and voluntarily amended his tax return before the IRS alerted him to a problem.
In the alternative, whether the assessment of a $308,064 penalty is an abuse of discretion on these facts.
Question Presented (AI Summary)
Whether the Government overreached by imposing any penalty on a taxpayer who owed no additional income tax and voluntarily amended his tax return before the IRS alerted him to a problem
Docket Entries
2022-12-05
Petition DENIED.
2022-11-09
DISTRIBUTED for Conference of 12/2/2022.
2022-11-07
Waiver of right of respondent United States to respond filed.
2022-10-06
Petition for a writ of certiorari filed. (Response due November 10, 2022)
2022-09-06
Application (22A201) granted by Justice Alito extending the time to file until October 6, 2022.
2022-08-31
Application (22A201) to extend the time to file a petition for a writ of certiorari from September 4, 2022 to October 6, 2022, submitted to Justice Alito.
Attorneys
Richard Collins
Jed Michael Silversmith — Law Office of Jed Silversmith LLC, Petitioner
United States
Elizabeth B. Prelogar — Solicitor General, Respondent