Judgment Issued.

Adjudged to be AFFIRMED. Kavanaugh, J., delivered the opinion of the Court, in which Roberts, C. J., and Sotomayor, Kagan, and Jackson, JJ., joined. Jackson, J., filed a concurring opinion. Barrett, J., filed an opinion concurring in the judgment, in which Alito, J., joined. Thomas, J., filed a dissenting opinion, in which Gorsuch, J., joined.

Adjudged to be AFFIRMED. Kavanaugh, J., delivered the opinion of the Court, in which Roberts C. J., and Sotomayor, Kagan, and Jackson, JJ., joined. Jackson, J., filed a concurring opinion. Barrett, J., filed an opinion concurring in the judgment, in which Alito, J., joined. Thomas, J., filed a dissenting opinion, in which Gorsuch, J., joined.

Argued. For petitioners: Andrew M. Grossman, Washington, D. C. For respondent: Elizabeth B. Prelogar, Solicitor General, Department of Justice, Washington, D. C.

Reply of petitioners Charles G. Moore, et ux. filed. (Distributed)

Brief amici curiae of Professors Akhil Reed Amar, et al. filed. (Distributed)

Brief amici curiae of John R. Brooks and David Gamage filed. (Distributed)

Brief amicus curiae of Amandeep S. Grewal filed.(11/6/2023) (Distributed)

Brief amici curiae of George A. Callas and Mindy Herzfeld filed. (Distributed)

Brief amicus curiae of The American College of Tax Counsel filed. (Distributed)

Brief amici curiae of Tax Economists filed. (Distributed)

Brief amici curiae of Main Street Alliance, et al. filed. (Distributed)

Brief amici curiae of Tax Law Center at NYU Law, et al. filed. (Distributed)

Brief amici curiae of Professors of Tax Law, Legal History, and Computational Science filed. (Distributed)

Brief amicus curiae of Alex Zhang filed. (Distributed)

Brief amici curiae of Arizona, et al. filed. (Distributed)

Brief amici curiae of Professors Bruce Ackerman, Joseph Fishkin and William E. Forbath filed. (Distributed)

Brief amici curiae of Tax Professors Donald B. Tobin and Ellen P. Aprill filed. (Distributed)

CIRCULATED

Brief amici curiae of Reuven Avi-Yonah, Clinton G. Wallace & Bret Wells filed. (Distributed)

Brief amicus curiae of American Tax Policy Institute filed. (Distributed)

Record received from the United States Court of Appeals for the Ninth Circuit. The record is electronic and is available on PACER.

Record requested from the United States Court of Appeals for the Ninth Circuit.

Brief of respondent United States filed.

SET FOR ARGUMENT on Tuesday, December 5, 2023.

Brief amicus curiae of L.E. Simmons filed.

Brief amicus curiae of Theodore P. Seto filed.

Brief amicus curiae of Calvin H. Johnson filed.

Motion to dispense with printing the joint appendix filed by petitioners GRANTED. Statement of Justice Alito. (Detached Opinion)

Brief amici curiae of Professors of Law and Linguistics in support of neither party filed.

Brief amicus curiae of Americans for Tax Reform filed.

Brief amici curiae of Sixteenth Amendment Insights, LLC and Jeffrey N. Schwartz filed.

Brief amicus curiae of FreedomWorks, Inc. filed.

Brief amici curiae of Southeastern Legal Foundation and Young America’s Foundation filed.

Brief amici curiae of The Buckeye Institute and National Federation of Independent Business Small Business Legal Center, Inc. filed.

Brief amicus curiae of National Taxpayers Union Foundation in support of neither party (September 7, 2023) filed.

Brief amici curiae of Former Attorney General Edwin Meese III, et al. filed.

Brief amicus curiae of Small Business and Entrepreneurship Council in support of neither party filed.

Brief amici curiae of Individual Taxpayers filed.

Brief amicus curiae of Independent Women's Law Center filed.

Brief amicus curiae of Liberty Justice Center filed.

Brief amicus curiae of Pacific Research Institute filed.

Brief amicus curiae of Atlantic Legal Foundation filed.

Brief amici curiae of West Virginia, et al. filed.

Brief amicus curiae of Landmark Legal Foundation filed.

Brief amici curiae of The Manhattan Institute for Policy Research, et al. filed.

Brief amicus curiae of Cato Institute filed.

Brief amicus curiae of Mark E. Berg filed.

Brief amici curiae of Saving America's Family Enterprises, et al. filed.

Brief amicus curiae of Philanthropy Roundtable filed.

Brief amicus curiae of The Chamber of Commerce of the United States of America filed.

Brief amici curiae of Stop Extraterritorial American Taxation and Association of Americans Resident Overseas filed.

Brief amicus curiae of Southern Policy Law Institute filed.

Brief amicus curiae of Professor Hank Adler filed.

Brief of petitioners Charles G. Moore, et ux. filed.

Motion to extend the time to file the briefs on the merits is granted. The time to file petitioners' brief on the merits is extended to and including August 30, 2023. The time to file respondent's brief on the merits is extended to and including October 16, 2023.

Motion to dispense with printing the joint appendix filed by petitioner Charles G. Moore, et ux.

Motion for an extension of time within which to file the briefs on the merits filed.

Petition GRANTED.

DISTRIBUTED for Conference of 6/22/2023.

Reply of petitioners Charles Moore, et al. filed. (Distributed)

DISTRIBUTED for Conference of 6/15/2023.

Brief of respondent United States in opposition filed.

Motion to extend the time to file a response is granted and the time is further extended to and including May 16, 2023.

Motion to extend the time to file a response from April 26, 2023 to May 16, 2023, submitted to The Clerk.

Brief amici curiae of The Pacific Research Institute, et al. filed.

Brief amicus curiae of Cato Institute filed.

Brief amicus curiae of Landmark Legal Foundation filed.

Brief amicus curiae of The Chamber of Commerce of the United States of America filed.

Brief amici curiae of The Manhattan Institute for Policy Research, et al. filed.

Brief amicus curiae of Southeastern Legal Foundation filed.

Brief amicus curiae of The Buckeye Institute filed.

Brief amicus curiae of Americans for Tax Reform filed.

Motion to extend the time to file a response is granted and the time is extended to and including April 26, 2023.

Motion to extend the time to file a response from March 27, 2023 to April 26, 2023, submitted to The Clerk.

Petition for a writ of certiorari filed. (Response due March 27, 2023)