tax-collection

13 cases — ← All topics

Case Title Lower Court Docketed Status Flags Tags Question Presented
25-7145 Lori Michelle Patitz, nka Lori Michelle Moody v. Commissioner of Internal Revenue Eleventh Circuit 2026-04-06 Pending Response WaivedIFP deductions internal-revenue-service statutory-interpretation tax-collection tax-court treasury-regulations 1. Does the Internal Revenue Service have the right to collect taxes from citizens that are not legally owed? 2. Can the Tax Court levy taxes and …
24-509 Kathlyn Moore v. United States Eleventh Circuit 2024-11-12 Denied Response Waived administrative-remedies disability-accommodation due-process pro-se-litigation sovereign-immunity tax-collection QUESTION 1: Does this Court agree that Petitioner's case was wrongly dismissed as a sanction for her inability to attend a deposition without accommod…
23-903 David E. Stone, et al. v. Commissioner of Internal Revenue Eleventh Circuit 2024-02-21 Denied Response Waived administrative-procedure-act bundled-mortgages executive-branch executive-branch-discretion income-tax internal-revenue-code mortgage-taxation sovereign-immunity tax-collection Whether the Commissioner, as an arm of the executive branch, has absolute discretion and sovereign immunity under the Administrative Procedure Act to …
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…
22-847 Virginia Silva-Navarro v. Roosevelt REO PR Corporation First Circuit 2023-03-07 Denied Response Waived civil-procedure diversity-jurisdiction due-process executive-power federal-court-jurisdiction federal-courts foreign-entity-litigation jurisdiction precedent standing supreme-court-precedent tax-collection 1. Are lower courts in the federal system to follow the case law of this Honorable Court? Or, the case law of this Honorable Court is merely persuasiv…
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…
22-294 County of Ontario, New York v. Brian Gunsalus, et al. Second Circuit 2022-09-28 Denied Response Waived bankruptcy-code bfp-v-resolution-trust-corp due-process foreclosure fraudulent-conveyance judicial-oversight real-estate-titles state-law tax-collection tax-foreclosure BFP v. Resolution Trust Corp., 511 U.S. 531 (1994) ("BFP") held the auction price obtained at a mortgage foreclosure conducted in accordance with the …
22-291 Brian H. McLane v. Commissioner of Internal Revenue Fourth Circuit 2022-09-27 Denied Amici (1)Response Waived appeals-hearing internal-revenue-service notice-of-deficiency overpayment-determination tax-appeals tax-collection tax-court tax-court-jurisdiction tax-liability tax-overpayment When the Internal Revenue Service (IRS) determines a taxpayer owes more than reported on a return, it may mail a notice of deficiency to the taxpayer.…
20-1210 Seneca County, New York v. Cayuga Indian Nation of New York Second Circuit 2021-03-02 Denied city-of-sherrill foreclosure immovable-property local-tax-authorities open-market open-market-land property-rights property-taxes tax-collection tribal-sovereign-immunity Whether tribal sovereign immunity bars local tax authorities from collecting lawfully imposed property taxes by foreclosing on real property that a tr…
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…
19-57 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…
18-367 Mary E. Jacobi v. New York Tax Appeals Tribunal, et al. New York 2018-09-20 Denied Response Waived 14th-amendment driver's-license due-process financial-hardship property-interest tax-collection tax-law The court below properly determined that Petitioner holds a substantial property interest in her driver license sufficient to warrant protection under…