| 25-719 |
Stanley Battat, et ux. v. Commissioner of Internal Revenue |
Eleventh Circuit |
2025-12-18 |
Pending |
|
administrative-procedure initial-determination irc-section-6751 managerial-approval tax-assessment tax-penalty |
Internal Revenue Code Section 6751(b)(1) provides that "[n]o penalty under this title shall be assessed unless the initial determination of such asses… |
| 25-205 |
Schuyler E. Cole, et al. v. City and County of Honolulu, Hawaii |
Hawaii |
2025-08-20 |
Denied |
Response Waived |
constitutional-law equal-protection fourteenth-amendment property-valuation tax-assessment tax-classification |
Whether a real property tax class that consists of certain residential properties that are distinguished from identical residential properties based s… |
| 24-238 |
Charles K. Breland, Jr. v. Commissioner of Internal Revenue |
Eleventh Circuit |
2024-09-03 |
Denied |
Response Waived |
bankruptcy-court consent-order iRS-claims res-judicata tax-assessment tax-liability |
In the Petitioner's Chapter 11 bankruptcy proceeding, the IRS filed multiple proofs of claim asserting that Petitioner owed federal income tax for yea… |
| 23-1037 |
Commissioner of Internal Revenue v. Isobel Berry Culp, et vir |
Third Circuit |
2024-03-19 |
Denied |
|
26-usc-6213 internal-revenue-service judicial-review petition-timeliness statutory-interpretation tax-assessment tax-court-jurisdiction tax-deficiency tax-procedure untimely-petition |
1. Whether 26 U.S.C. 6213(a) grants the Tax Court jurisdiction to review an untimely petition for redetermination of a tax deficiency?
2. Even assumi… |
| 23-762 |
Sam Silverberg v. District of Columbia, et al. |
District of Columbia |
2024-01-17 |
Denied |
Response Waived |
appellate-discretion constitutional-challenge constitutional-challenges exclusive-jurisdiction federal-jurisdiction property-rights state-revenues subject-matter-jurisdiction tax-assessment tax-assessments |
Whether the exclusive jurisdiction to shield local tax assessments from constitutional challenges in a federal court to protect state revenues can be … |
| 23-614 |
Rocky Branch Timberlands LLC v. United States, et al. |
Eleventh Circuit |
2023-12-07 |
Denied |
Response Waived |
anti-injunction-act civil-procedure due-process irs iRS-procedure judicial-review tax-assessment tax-collection taxpayer-rights |
Whether the Anti-Injunction Act's bar on lawsuits for the purpose of restraining the assessment or collection of taxes also bars courts from enforcing… |
| 23-443 |
MMN Infrastructure Services, LLC, Successor in Interest to Vectren Infrastructure Services Corp. v. Michigan Department of Treasury |
Michigan |
2023-10-27 |
Denied |
Amici (3)Response Waived |
corporate-disclosure extraterritorial-taxation factor-representation fair-apportionment interstate-commerce short-tax-year tax-apportionment tax-assessment temporal-element |
1. Whether, to comply with the requirements of fair apportionment and the prohibition on extraterritorial taxation, a state must include in its state … |
| 23-5703 |
Festus Okwudili Ohan v. ABN AMRO, et al. |
Ninth Circuit |
2023-10-03 |
Denied |
Relisted (2)IFP |
civil-liberties civil-rights conspiracy constitutional-rights due-process judicial-procedure legal-interpretation property property-rights takings tax-assessment |
Question not identified. |
| 23-233 |
Antero Resources Corporation v. Matthew R. Irby, West Virginia Tax Commissioner, et al. |
West Virginia |
2023-09-13 |
Denied |
Response Waived |
dormant-commerce-clause in-state-sellers interstate-commerce natural-gas out-of-state-sellers post-production-expenses property-tax tax-assessment |
For the tax assessments at issue in these appeals, West Virginia did not allow owners of natural gas wells to deduct their actual post-production expe… |
| 22-6692 |
Jerez Coleman v. Maryland |
Maryland |
2023-02-02 |
Denied |
IFP |
administrative-review civil-rights constitutional-rights due-process equal-protection procedural-burden property-rights property-tax takings tax-assessment tax-sale |
Question not identified. |
| 22-6456 |
Paul D. Weldon v. United States |
Ninth Circuit |
2023-01-04 |
Denied |
Response WaivedIFP |
14th-amendment attorney-general-authorization due-process irs jurisdictional-challenge tax-assessment tax-collection third-party-filing third-party-filings |
Observing that an "assessment is expected to be rational, not flawless. Caulfield v. Comm V, 33 F.3d 991, 993 (8th Cir. 1994). Material Issue Existing… |
| 22-473 |
Hancock County Land Acquisitions, LLC v. United States, et al. |
Eleventh Circuit |
2022-11-18 |
Denied |
Response Waived |
anti-injunction-act civil-procedure due-process irs iRS-procedure judicial-review tax-assessment tax-collection tax-law taxpayer-rights |
Whether the Anti-Injunction Act's bar on lawsuits for the purpose of restraining the assessment or collect of taxes also bars courts from enforcing la… |
| 22-5386 |
Pamela Bond v. McKean County, Pennsylvania |
Third Circuit |
2022-08-18 |
Denied |
Response WaivedIFP |
civil-rights due-process judicial-interpretation pennsylvania-law property property-tax real-estate real-estate-law tax-assessment tax-delinquency taxation vehicle-transfer |
The 2005 Dodge Caravan owned by the Petitioner in this case was still registered in the State of Pennsylvania when she signed it over to Bednar Metals… |
| 21-1457 |
Quiller Barnes v. Commissioner of Internal Revenue |
Ninth Circuit |
2022-05-18 |
Denied |
Response Waived |
due-process internal-revenue-regulations irs-regulations pension-funds pension-rollover retirement-funds rollover statute-of-limitations tax-assessment tax-law |
Were the Petitioner's 1996 Pension funds from Pacific Bell Telephone Company, which was properly rolled over within 60 days of his retirement, per his… |
| 20-1583 |
Jeffrey Olson v. Minnesota Commissioner of Revenue |
Minnesota |
2021-05-14 |
Denied |
Response Waived |
administrative-procedure appeal commissioner-order commissioner's-order due-process mail-notice ordinary-mail procedural-due-process tax-appeal tax-assessment tax-procedure |
Under Minnesota tax procedure, the central procedural event is the issuance of a Commissioner's Order, by which the Minnesota Commissioner of Revenue … |
| 20-880 |
Michael H. Holland, as Trustee for the United Mine Workers of America Combined Benefit Fund and United Mine Workers of America 1992 Benefit Plan, et al. v. Westmoreland Coal Company, et al. |
Fifth Circuit |
2021-01-04 |
Denied |
Response RequestedRelisted (2) |
anti-injunction-act bankruptcy-code circuit-split coal-act south-carolina-v-regan statutory-interpretation tax tax-assessment |
1. Is the South Carolina v. Regan exception to the Anti-Injunction Act available to debtors who want to avoid paying a tax for reasons unrelated to th… |
| 20-620 |
Anthony Dwayne Williams, et al. v. Commissioner of Internal Revenue |
Fifth Circuit |
2020-11-09 |
Denied |
Response Waived |
constitutional-protections constitutional-rights due-process excise-tax federal-income-tax internal-revenue-code nontaxpayer nontaxpayer-status statutory-notice tax-assessment tax-liability taxpayer |
Should the United States Federal Income Tax be viewed in a different way (or perspective) when determining the assessment for the liability or penalty… |
| 20-316 |
Maria Pappas, Cook County Treasurer, et al. v. A.F. Moore & Associates, Inc., et al. |
Seventh Circuit |
2020-09-10 |
Denied |
Amici (1) |
civil-rights comity-doctrine due-process equal-protection real-estate real-estate-assessment tax-assessment tax-injunction-act tax-refund |
1. Whether the Equal Protection Clause mandates that a real estate taxpayer seeking a refund based on an over assessment of real property be able to c… |
| 20-215 |
Richard Bernholz v. Internal Revenue Service |
Second Circuit |
2020-08-25 |
Denied |
Response Waived |
federal-tort-claims-act government-liability immunity internal-revenue-service sovereign-immunity statutory-interpretation tax-assessment tax-collection |
The question presented is whether any conduct by the Internal Revenue Service which may broadly be construed as a mechanism for the assessment and col… |
| 19-8534 |
Robert W. Johnson v. Performant Recovery, Inc., et al. |
Ninth Circuit |
2020-05-23 |
Denied |
IFP |
civil-procedure constitutional-rights due-process jurisdiction standing tax-assessment |
Question not identified. |
| 19-7576 |
James Anthony Davis v. Angleton Independent School District, et al. |
Texas |
2020-02-05 |
Denied |
Response WaivedRelisted (2)IFP |
civil-procedure due-process government-interference necessary-parties property-rights res-judicata taking-clause takings tax-assessment |
1. Whether the Petitioner could be liable for the 2012 taxes as he was not the property owner on January 01,2012.
2. Whether the government's interfe… |
| 19-261 |
Steven T. Waltner, et ux. v. Commissioner of Internal Revenue |
Ninth Circuit |
2019-08-28 |
Denied |
Response WaivedRelisted (2) |
appellate-jurisdiction collateral-estoppel due-process informal-notice statute-of-limitations sua-sponte-sanction tax-appeal tax-assessment tax-assessment-statute-of-limitations tax-code tax-court tax-return valid-return |
Whether the court below, in conflict with its own precedents as well as those of this Court and five other Circuit Courts of Appeal, erred in holding … |
| 19-5151 |
Jeffrey T. Maehr v. United States |
Federal Circuit |
2019-07-11 |
Denied |
Response WaivedRelisted (2)IFP |
16th-amendment due-process findings-of-fact grand-jury-access income-definition irs-actions standing standing-precedent stare-decisis tax-assessment tax-assessments tax-levies |
1. Can the IRS/United States government Respondent and lower courts consistently call U.S. Supreme Court standing case precedent (stare decisis) on th… |
| 19-57 |
Donald Dewees v. United States |
District of Columbia |
2019-07-09 |
Denied |
Response Waived |
administrative-procedure due-process eighth-amendment equal-protection excessive-fines international-tax international-taxation streamlined-filing-compliance-procedures tax-assessment tax-collection tax-compliance tax-convention tax-penalties |
1. Did the lack of a meaningful review of the assessment and collection of a tax under the Convention violate Dewees' right to due process?
2. Did th… |
| 18-9433 |
Timothy J. Stubbs v. United States |
Tenth Circuit |
2019-05-29 |
Denied |
Response WaivedIFP |
burden-of-proof criminal-activity financial-records financial-transparency fraud fraud-or-deceit kawashima-v-holder sentencing-enhancement sophisticated-means tax-assessment tax-evasion |
Does the Government meet its burden of proof in a tax evasion case (as opposed to failure to file) where the financial records of the accused are trut… |
| 18-1468 |
United Mine Workers of America Combined Benefit Fund, et al. v. Andre M. Toffel, as Chapter 7 Trustee for Walter Energy Inc., et al. |
Eleventh Circuit |
2019-05-24 |
Denied |
Response Waived |
1992-plan-premiums anti-injunction-act bankruptcy-code bankruptcy-code-section-1114 circuit-split coal-act south-carolina-v-regan statutory-interpretation tax-assessment tax-validity |
1. Whether the South Carolina v. Regan exception to the Anti-Injunction Act applies only in this Court and, if not, whether it applies only to litigan… |
| 18-9099 |
Jean-Gespere Pierre v. Alliance Security Services, et al. |
Second Circuit |
2019-05-03 |
Denied |
IFP |
civil-procedure-standing-due-process-takings-pate ' 'civil-procedure" ' 'civil-rights" ' 'due-process" ' 'patent' ' 'standing" ' 'takings" administrative-law civil-procedure due-process jurisdictional-challenge property-rights tax-assessment |
Question not identified. |
| 18-792 |
Ronald Leroy Satterlee v. Alicia Miller-Degase, Assessor of Douglas County, Missouri, et al. |
Missouri |
2018-12-20 |
Denied |
Response Waived |
civil-rights constitutional-rights contract-rights due-process government-authority jurisdiction jurisdiction-challenge presumption-of-innocence property-rights property-tax right-of-contract tax-assessment taxation |
The Question Presented for Review is whether or not this Appellant Has Right To Life, Liberty, Property and Pursuit of Happiness, the Right To Presump… |
| 18-297 |
Eric White, et al. v. Barbara D. Underwood, Attorney General of New York, et al. |
New York |
2018-09-07 |
Denied |
Amici (1)Response Waived |
canons-of-construction federal-indian-law indian-law indian-rights indian-treaty-rights native-american-rights new-york-indians seneca-nation sovereign-immunity state-taxation statutory-interpretation supreme-court-precedent tax-assessment treaty-interpretation tribal-sovereignty |
The decision below ruled that New York's promise to the Seneca Nation of Indians to refrain from assessing taxes "for any purpose whatever, upon any I… |
| 18-205 |
Northern California Water Association, et al. v. California State Water Resources Control Board, et al. |
California |
2018-08-16 |
Denied |
Response Waived |
central-valley-project federal-property intergovernmental-immunity preemption property-rights sovereign-immunity state-taxation state-water-board supremacy-clause tax-assessment taxation water-contractors water-contracts water-rights |
Is a California statute imposing a direct tax on the United States' property interest in water constitutional if it is applied in a manner that passes… |