No. 22-598
Arthur Bedrosian v. United States, et al.
Amici (1)Response RequestedResponse WaivedRelisted (2)
Tags: civil-penalty civil-procedure due-process foreign-account foreign-account-reporting irs objective-standard statutory-interpretation subjective-standard tax willful-violation willfulness
Key Terms:
Patent JusticiabilityDoctri
Patent JusticiabilityDoctri
Latest Conference:
2023-06-15
(distributed 2 times)
Question Presented (from Petition)
Whether willfulness under 31 U.S.C. § 5321(a)(5)(C) should be determined according to a subjective, rather than objective, standard that focuses on an individual's knowledge and intent in failing to disclose a foreign account.
Question Presented (AI Summary)
Whether willfulness under 31 U.S.C. § 5321(a)(5)(C) should be determined according to a subjective, rather than objective, standard that focuses on an individual's knowledge and intent in failing to disclose a foreign account
Docket Entries
2023-06-20
Petition DENIED.
2023-05-30
DISTRIBUTED for Conference of 6/15/2023.
2023-05-26
Reply of petitioner Arthur Bedrosian filed. (Distributed)
2023-05-15
Brief of respondents United States, et al. in opposition filed.
2023-04-07
Motion to extend the time to file a response is granted and the time is further extended to and including May 15, 2023.
2023-04-06
Motion to extend the time to file a response from April 14, 2023 to May 15, 2023, submitted to The Clerk.
2023-02-27
Motion to extend the time to file a response is granted and the time is extended to and including April 14, 2023.
2023-02-24
Motion to extend the time to file a response from March 15, 2023 to April 14, 2023, submitted to The Clerk.
2023-02-13
Response Requested. (Due March 15, 2023)
2023-02-01
DISTRIBUTED for Conference of 2/17/2023.
2023-01-30
Brief amicus curiae of The Center for Taxpayer Rights filed. (Distributed)
2023-01-26
Waiver of right of respondent United States, et al. to respond filed.
2022-12-27
Petition for a writ of certiorari filed. (Response due January 30, 2023)
Attorneys
Arthur Bedrosian
Ian M. Comisky — Fox Rothschild LLP, Petitioner
The Center for Taxpayer Rights
Zhanna Angert Ziering — Moore Tax Law Group LLC, Amicus
United States, et al.
Elizabeth B. Prelogar — Solicitor General, Respondent