tax-court
36 cases — ← All topics
| Case | Title | Lower Court | Docketed | Status | Flags | Tags | Question Presented |
|---|---|---|---|---|---|---|---|
| 25A778 | Stephanie Murrin v. Commissioner of Internal Revenue | Third Circuit | 2026-01-05 | Application | innocent-taxpayer iRS-assessment limitations-period section-6501 tax-court tax-fraud | Whether the IRS can assess taxes beyond the usual three-year deadline when the taxpayer's preparer intended to file a false or fraudulent return, but … | |
| 25-5402 | Martin G. Plotkin v. Commissioner of Internal Revenue | Eleventh Circuit | 2025-08-19 | Denied | Response WaivedIFP | administrative-hearing due-process judicial-bias levy-action recusal tax-court | 1. Do the intentional, deliberate, and purposeful actions and statements of Tax Court Judge Morrison, whether derived from 'judicial' or 'extrajudicia… |
| 25-28 | Claude Franklin Sanders v. Commissioner of Internal Revenue | Sixth Circuit | 2025-07-09 | Denied | Response Waived | administrative-procedure-act agency-filing federal-register income-tax jurisdiction tax-court | QUESTION 1: Is the IRS required by 5 U.S.C. §552(a)(l) to publish in the Federal Register the places where federal income tax returns are to be filed?… |
| 24-715 | Thomas Shands v. Commissioner of Internal Revenue | District of Columbia | 2025-01-03 | Denied | Response Waived | internal-revenue-service judicial-review statutory-interpretation subject-matter-jurisdiction tax-court whistleblower-award | I. Whether the IRS can deprive the United States Tax Court of subject matter jurisdiction to review the IRS's denial of a mandatory whistleblower awar… |
| 24A567 | Frank Bibeau v. Commissioner of Internal Revenue | Eighth Circuit | 2024-12-11 | Presumed Complete | certiorari eighth-circuit extension-of-time judicial-review petition tax-court | Question not identified. | |
| 24-416 | Commissioner of Internal Revenue v. Jennifer Zuch | Third Circuit | 2024-10-15 | Judgment Issued | Amici (4) | administrative-review internal-revenue-service jurisdictional-challenge pre-deprivation-proceeding tax-court tax-levy | Whether a proceeding under 26 U.S.C. 6330 for a pre-deprivation determination about a levy proposed by the Internal Revenue Service to collect unpaid … |
| 23-1322 | James W. Tindall v. Commissioner of Internal Revenue | District of Columbia | 2024-06-18 | Denied | Response WaivedRelisted (2) | administrative-record agency-record discovery judicial-precedent standard-of-review stare-decisis subject-matter-jurisdiction tax-court tax-court-review whistleblower whistleblower-claim | 1.) Whether this dispute is even ripe for review by the Supreme Court of the United States ("this Court") when Respondent's agency administrative reco… |
| 23A738 | Commissioner of Internal Revenue v. Isobel Berry Culp, et vir | Third Circuit | 2024-02-08 | Presumed Complete | assessment judicial-review petition statutory-lien tax-court tax-deficiency | Question not identified. | |
| 23-653 | Ritchie N. Stevens, et al. v. Commissioner of Internal Revenue | Ninth Circuit | 2023-12-15 | Denied | Response Waived | civil-procedure irs net-operating-loss partnership partnership-audit tax tax-court tax-law tefra tefra-regime unsigned-returns | 1. Whether a net operating loss carryover to a future year that is an "affected item" under the TEFRA Partnership audit regime can be included within … |
| 23-4 | John Thomas Minemyer v. Commissioner of Internal Revenue | Tenth Circuit | 2023-06-30 | Denied | Response Waived | internal-revenue-code irs-penalties legislative-history legislative-intent penalty-assessment statutory-interpretation supervisory-approval tax-code tax-court | Does the legislative history and intent combined with the Tax Court Judicial history, the internal revenue manual instructions, and the Supreme Courts… |
| 22-6797 | Dominick Galluzzo v. Internal Revenue Service | Third Circuit | 2023-02-16 | Denied | Response WaivedRelisted (2)IFP | attorney-misconduct bankruptcy bankruptcy-procedure irs iRS-assessment judicial-misconduct proof-of-claim tax-court tax-dispute venue venue-selection | Was I mis represented at bankruptcy by my attorney not asking for attachments to PROOF OF CLIAM accoding to rule 3001 and B10 (exhibits H & I) At 20… |
| 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.… |
| 22-9 | Whirlpool Financial Corporation, et al. v. Commissioner of Internal Revenue | Sixth Circuit | 2022-07-05 | Denied | Amici (3)Response RequestedResponse WaivedRelisted (2) | administrative-law income-taxation internal-revenue-code regulations sixth-circuit sixth-circuit-precedent statutory-interpretation tax-court tax-law treasury-regulations | Whether the divided Sixth Circuit properly held—in conflict with precedent of this Court and settled administrative-law principles—that a statute that… |
| 21-1528 | Patrick Combs, aka Patrick Davy Combs v. Commissioner of Internal Revenue | Ninth Circuit | 2022-06-06 | Denied | Response Waived | anticipatory-assignment-of-income church civil-rights constitutional-rights constructive-dividends due-process ninth-circuit tax tax-court | Whether the Ninth Circuit Court committed treason to the Constitution and denied Petitioner his due process of Law by affirming the Tax Court's Order … |
| 21-1035 | Joshua Harris v. Commissioner of Internal Revenue | Second Circuit | 2022-01-24 | Denied | Response Waived | brady-doctrine civil-procedure constitutional-rights discovery discovery-violation due-process evidence-suppression fair-trial in-limine tax-court | 1. Whether the U.S Tax Court and the Second Circuit conflicts with the United States Constitution, Amendment 6 and the Fourteenth Amendment to a fair … |
| 21-6737 | James P. Donoghue, et ux. v. Commissioner of Internal Revenue | First Circuit | 2021-12-28 | Denied | Response WaivedIFP | general-intent judicial-oath judicial-regulation judicial-remand judicial-review objective-review perjury specific-intent statutory-interpretation tax-court | 1. Pursuant to 26 C.F.R. § 1.183, whether the lower courts' errored when framing decision under the doctrine of general-intent; using subjective deduc… |
| 21-610 | Louis S. Shuman, et ux. v. Commissioner of Internal Revenue | Fourth Circuit | 2021-10-26 | Denied | Response WaivedRelisted (2) | court-rules due-process federal-court-rules federal-statutes fifth-amendment jurisdiction jurisdictional-grounds tax-court | Whether an Order of the United States Tax Court is deemed final, and legally enforceable, including enforcement on jurisdictional grounds, when the U.… |
| 21-409 | Anthony Italo Provitola, et ux. v. Commissioner of Internal Revenue | Eleventh Circuit | 2021-09-15 | Denied | Response Waived | appellate-jurisdiction appellate-rules article-iii circuit-court civil-procedure federal-rules judicial-review procedural-rules standing summary-judgment tax-court | Whether the United States Circuit Courts of Appeal have the power to override federal statutory appellate rules with their decision to render unappeal… |
| 20-1726 | Roy J. Meidinger v. United States | Federal Circuit | 2021-06-15 | Denied | Response WaivedRelisted (2) | administrative-procedure contract contractual-relationship federal-claims-court iRS-jurisdiction jurisdiction statutory-interpretation tax-court tax-relief-and-healthcare-act-of-2006 tax-whistleblower whistleblower whistleblower-claims | The questions presented for review, deal with aspects of a single subject matter reference, The Tax Relief and Health Care Act of 2006, Pub. L. 109 —4… |
| 20-1472 | Boechler, P.C. v. Commissioner of Internal Revenue | Eighth Circuit | 2021-04-21 | Judgment Issued | Amici (6) | claim-processing-rule equitable-tolling internal-revenue-code jurisdiction jurisdictional-requirement tax-court tax-law time-limit | Whether the time limit in Section 6330(d)(1) is a jurisdictional requirement or a claim-processing rule subject to equitable tolling. |
| 20-1267 | Ronald E. Byers v. Commissioner of Internal Revenue | District of Columbia | 2021-03-12 | Denied | Response Waived | certiorari certiorari-writ circuit-split decision-finality finality fraud-exception fraud-on-the-court jurisdictional-statute post-decision-motions post-decision-relief tax-court | When the Supreme Court of the United States denies a taxpayer a certiorari writ in a case begun in the United States Tax Court, 26 U.S.C. § 7481(a)(2)… |
| 19-1343 | In Re Edward Starling | 2020-06-05 | Rehearing | Relisted (3) | article-i article-i-court civil-procedure due-process income-tax-refund judicial-authority jurisdiction quasi-in-rem question-not-identified tax-court tax-court-jurisdiction title-26 | (1) The Scope Of Complete Exclusive Jurisdictional Authority of the United States Tax Court Under Article I of The United States Constitution Upon Tit… | |
| 19-7580 | Constantine Gus Cristo v. Commissioner of Internal Revenue | Ninth Circuit | 2020-02-06 | Denied | Response WaivedIFP | 26-usc-7491 9th-circuit burden-of-proof credible-evidence federal-agent irs-restructuring-and-reform-act-of-1998 ninth-circuit statutory-interest tax-court taxpayer-rights unconstitutional-conduct | The Fourth Amendment guarantees that the people shall have a right: "to be secure in their persons, houses, papers and effects, against unreasonable s… |
| 19-536 | Bocilla Island Seaport, Inc., fka Highpoint Tower Technology, Inc. v. Commissioner of Internal Revenue | Eleventh Circuit | 2019-10-24 | Denied | Response Waived | basis-adjustment deficiency-determination due-process partner-level partner-level-penalty partner-level-proceeding partnership-basis penalty penalty-imposition reasonable-cause statutory-interpretation tax-court tax-court-jurisdiction tax-procedure united-states-v-woods | This Tax Court partner-level penalty jurisdiction case raises these four interrelated issues: 1) Should "each partner's outside basis [in his partner… |
| 19-488 | Steven T. Waltner, et ux. v. Commissioner of Internal Revenue | Ninth Circuit | 2019-10-15 | Denied | Relisted (2) | administrative-law administrative-regulation certified-mail circuit-split common-law-mailbox-rule due-process-challenge irc-section-7502 mailbox-rule postmark statutory-interpretation tax-court tax-filing | 1. Whether the Ninth Circuit incorrectly held, in conflict with precedents in the Third, Eighth, Ninth, and Tenth Circuits, that under 26 CFR §301.750… |
| 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 … |
| 19-175 | Brad S. Francis, et al. v. Commissioner of Internal Revenue | Eighth Circuit | 2019-08-07 | Denied | Response Waived | administrative-procedure-act agency-misconduct appellate-procedure due-process jurisdiction notice-of-deficiency personal-jurisdiction reasoned-opinion statutory-notice subject-matter-jurisdiction tax-court tax-court-jurisdiction | The Eighth Circuit has departed from the accepted and usual course of judicial proceedings under Federal Rule of Appellate Procedure 47(a) and, in so … |
| 18A1313 | Steven T. Waltner, et ux. v. Commissioner of Internal Revenue | Ninth Circuit | 2019-06-14 | Presumed Complete | collateral-estoppel deficiency sanctions statute-of-limitations tax-court tax-return | Question not identified. | |
| 18-1520 | Michael A. Tricarichi, Transferee v. Commissioner of Internal Revenue | Ninth Circuit | 2019-06-06 | Denied | Response Waived | 9th-circuit federal-income-tax fraudulent-transfer internal-revenue-code irc-6901 state-law tax-court third-party-conduct transferee-liability | Whether a tax court in applying fraudulent transfer principles for imposing transferee liability with respect to a taxpayer must utilize the fraudulen… |
| 18-1270 | Henry M. Jagos, et ux. v. Commissioner of Internal Revenue | Sixth Circuit | 2019-04-03 | Denied | Response Waived | administrative-law administrative-procedure circuit-court-split circuit-split civil-procedure due-process eighth-circuit judicial-review jurisdiction notice-of-deficiency sixth-circuit standing tax-appeals tax-court tax-court-jurisdiction tax-procedure | 1. Did the Tax Court lack jurisdiction when it had no facially legitimate notice of deficiency? 2. Did the Sixth Circuit Court Of Appeals properly co… |
| 18-8507 | Randall Jennette v. Commissioner of Internal Revenue | Third Circuit | 2019-03-21 | Denied | Response WaivedRelisted (2)IFP | 28-usc-1738 admiralty-law admiralty-maritime full-faith-and-credit maritime-contract relief-sought statutory-interpretation subject-matter-jurisdiction tax-court | Whether Tax Court, had subject mattter jurisdiction, under it's Admiralty/Maritime Jurisdictions. To grant Appellee, relief sought in the absence of … |
| 18-1133 | Henry J. Langer, et ux. v. Commissioner of Internal Revenue | Eighth Circuit | 2019-03-01 | Denied | Response Waived | 8th-circuit burden-of-proof civil-procedure clear-and-convincing-evidence penalty-assessment tax-court tax-court-review tax-evasion tax-fraud tax-liability tax-penalties | Whether Respondent has proved by clear and convincing evidence that Henry J. Langer is liable for the fraud penalty for the years 2011, 2012, and 2013… |
| 18-1100 | Wayne D. Ramsay v. Commissioner of Internal Revenue | Fifth Circuit | 2019-02-22 | Denied | Response Waived | administrative-law administrative-procedure deficiency deficiency-interest interest internal-revenue-service jurisdiction statutory-interpretation tax tax-court tax-law | DOES THE U.S. TAX COURT HAVE JURISDICTION TO DETERMINE DEFICIENCY INTEREST ASSESSED BY THE INTERNAL REVENUE SERVICE? |
| 18-1003 | Norma L. Slone, et al. v. Commissioner of Internal Revenue | Ninth Circuit | 2019-02-01 | Denied | Response Waived | appellate-review clearly-erroneous fact-finding factual-findings judicial-procedure standard-of-review tax tax-court tax-court-deference | Whether a court of appeals may reverse a fact-dependent ruling of the tax court without articulating any standard of review, finding that any of the t… |
| 18-6128 | Norman Douglas Diamond v. Commissioner of Internal Revenue | District of Columbia | 2018-09-28 | Denied | Response WaivedRelisted (2)IFP | due-process fraud irs irs-corruption jurisdiction jurisdictional-notice overpayment-refund statutory-guarantee statutory-notice tax tax-court tax-court-jurisdiction tax-deficiency tax-evasion tax-fraud | Former IRS employees have been for fraud and embezzlement of income tax withholdings originally collected legally. The IRS still does not credit petit… |
| 18-51 | Brad Francis, et ux. v. Commissioner of Internal Revenue | Eighth Circuit | 2018-07-10 | Denied | Response Waived | administrative-law civil-procedure due-process eighth-circuit jurisdictional-review personal-jurisdiction standing subject-matter-jurisdiction tax tax-court | This is a call for the Court to exercise its supervisory power over the lower courts: Specifically, this case seeks review of the Eighth Circuit Court… |