No. 25-680
Bernard T. Swift, Jr., et ux. v. Commissioner of Internal Revenue
Amici (1)
Tags: administrative-procedure internal-revenue-code penalty-assessment statutory-construction supervisory-approval tax-law
Latest Conference:
N/A
Question Presented (from Petition)
When must an IRS employee secure written supervisory approval for a penalty assessment to be valid?
Question Presented (AI Summary)
When must an IRS employee secure written supervisory approval for a penalty assessment to be valid?
Docket Entries
2026-02-02
Motion to extend the time to file a response is granted and the time is further extended to and including March 13, 2026.
2026-01-30
Motion of Federal Respondents for an extension of time submitted.
2026-01-30
Motion to extend the time to file a response from February 11, 2026 to March 13, 2026, submitted to The Clerk.
2026-01-12
Motion to extend the time to file a response is granted and the time is extended to and including February 11, 2026.
2026-01-09
Brief amicus curiae of Donald Miller, Jr. filed.
2026-01-08
Motion to extend the time to file a response from January 12, 2026 to February 11, 2026, submitted to The Clerk.
2025-12-09
Petition for a writ of certiorari filed. (Response due January 12, 2026)
Attorneys
Bernard T. Swift, Jr., et al.
Donald Miller, Jr.
Joshua Stephen Johnson — Vinson & Elkins LLP, Amicus
Federal Respondents
D. John Sauer — Solicitor General, Respondent