No. 25-684

Malcolm Curtis, et ux. v. Department of the Treasury, et al.

Lower Court: Ninth Circuit
Docketed: 2025-12-11
Status: Denied
Type: Paid
Response Waived
Tags: burden-of-proof due-process equal-protection income-reporting judicial-presumption tax-law
Latest Conference: 2026-01-09
Question Presented (from Petition)

Whether granting the IRS a judicial presumption of correctness violates due process and equal protection in a case where a taxpayer is accused of not reporting income from a 'legal source', when the IRS fails to introduce any evidence that the taxpayer actually received the alleged unreported income?

Question Presented (AI Summary)

Whether granting the IRS a judicial presumption of correctness violates due process and equal protection when the IRS fails to introduce evidence of unreported income from a legal source

Docket Entries

2026-01-12
Petition DENIED.
2025-12-23
DISTRIBUTED for Conference of 1/9/2026.
2025-12-15
Waiver of Dept. of Treasury, et al. of right to respond submitted.
2025-12-15
Waiver of right of respondent Dept. of Treasury, et al. to respond filed.
2025-11-01
Petition for a writ of certiorari filed. (Response due January 12, 2026)

Attorneys

Dept. of Treasury, et al.
D. John SauerSolicitor General, Respondent
Malcolm Curtis
Rebekah Len ParkerLaw Office of Rebekah L. Parker, Petitioner