tax-deficiency

8 cases — ← All topics

Case Title Lower Court Docketed Status Flags Tags Question Presented
24-659 Brian D. Swanson v. Commissioner of Internal Revenue Eleventh Circuit 2024-12-18 Denied Response WaivedRelisted (2) administrative-law constitutional-interpretation income-tax tax-deficiency territory-clause uniformity-clause In light of this Court recent holding in Moore etux v. United States (2024), that income taxes are indirect taxes subject to the Constitution 's Unifo…
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…
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.
22-729 Thomas D. Selgas v. United States Fifth Circuit 2023-02-06 Denied Response Waived 26-usc-7201 criminal-tax criminal-tax-law irc-section-371 irc-section-7201 tax-conspiracy tax-deficiency tax-due-and-owing tax-evasion 1. Whether a person charged with only evasion of the payment of taxes under 26 U.S.C. §7201 can be convicted, when there is no tax due and owing. 2. …
22-114 Mark Anthony Blommer v. Commissioner of Internal Revenue Ninth Circuit 2022-08-08 Denied Response Waived administrative-law due-process irs irs-procedure non-statutory-notices statutory-compliance substitute-return substitutes-for-return tax-deficiency taxpayer-rights 1. For a notice of deficiency to exist, must not said notices comply with the statutes? 2. If a taxpayer files a statement as instructed to by the In…
21-7875 Freya D. Pearson v. United States Eighth Circuit 2022-05-16 Denied Response WaivedRelisted (2)IFP appellate-procedure constitutional-right direct-appeal due-process effective-counsel ineffective-assistance notice-of-deficiency notice-of-withdrawal notice-requirement prosecutorial-misconduct tax-deficiency Does a defendant have a Constitutional Right to Effective Counsel from beginning to end, while in their Direct Appeal? And if that defendant has not w…
19-10 James W. Smith v. United States Tenth Circuit 2019-07-01 Denied Response Waived assessment collection due-process internal-revenue-code mandatory-provisions notice payment sovereign-capacity statute-of-limitations tax-court-jurisdiction tax-deficiency transferee-liability 1. The Meaning of "Shall" in the Internal Revenue Code. Sections 6501(a), 6213(a), and 6901(a) of the Internal Revenue Code all provide that the Gove…
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…