tax-liability

16 cases — ← All topics

Case Title Lower Court Docketed Status Flags Tags Question Presented
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…
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.…
21-7531 Michael G. Peters v. City of Houston, Texas, et al. Fifth Circuit 2022-04-04 Denied IFP certiorari-petition civil-procedure civil-rights court-review due-process federal-tax-code free-speech legal-procedure standing statutory-interpretation takings tax-liability Question not identified.
21-1203 In Re Roger Rowe 2022-03-02 Denied Response WaivedRelisted (2) agency-procedure civil-procedure civil-rights constitutional-rights due-process judicial-proceedings judicial-review lien standing statute-of-limitations tax-liability 1. Whether Petitioner is entitled to relief from a judgment and orders from the Second Circuit court, which conflicts with a decision of this Court …
21-1067 Ra Nu Ra Khuti Amen Bey v. United States Federal Circuit 2022-02-01 Denied Response Waived civil-rights constitutional-rights due-process federal-jurisdiction federal-questions original-issue-discount secured-party-creditor standing takings tax tax-liability 1. Whether plaintiffs ' erroneously given "inferior status " and denied the right to redress the UNITED STATES on obligations such as certificates of…
21-338 Gary S. Christensen v. United States Ninth Circuit 2021-09-02 Denied Response Waived 16th-amendment criminal-tax due-process equal-protection federal-jurisdiction irs-determination precedent-interpretation restitution sixteenth-amendment tax-liability Where no determination of federal tax liability has been made by the IRS and the court of appeals has ruled patently contrary to this court's decision…
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…
20-460 Richard E. Boggs v. United States Fourth Circuit 2020-10-09 Denied Response Waived 5th-amendment administrative-determination due-process fifth-amendment irs property-seizure tax-liability withholding-certificate 1) Did the Internal Revenue Service (IRS) deprive the petitioner of his Constitutional Fifth Amendment right to due process when it failed to offer a …
19-1178 Robert K. Zabka, et ux. v. United States, et al. Seventh Circuit 2020-03-27 Denied Response Waived appellate-jurisdiction civil-procedure civil-procedure-final-judgment-receivership-appeal conflict-of-laws conflicting-precedent due-process federal-courts final-judgment jurisdiction net-operating-loss partnership-property receivership standing tax-liability timeliness The Circuits are Conflicted The First and Second Circuits are in conflict with the Seventh Circuit as to whether the order appointing a receiver is t…
19-969 John M. Marshall, et al. v. Commissioner of Internal Revenue Ninth Circuit 2020-02-03 Denied Amici (1)Response Waived creditor-rights federal-law property-transfer recharacterization state-law stern-v-commissioner tax-law tax-liability transaction-recharacterization Whether, when the true form of the transaction is at issue, the court must determine whether state law would permit a private creditor to collapse or …
19-6338 Gerald Nelson v. Commissioner of Internal Revenue Second Circuit 2019-10-22 Denied Response WaivedRelisted (2)IFP arbitration arbitration-award back-pay back-pay-settlement civil-rights due-process gross-income gross-income-taxation section-1983 tax tax-law tax-liability unemployment unemployment-benefits 1. 26 U.S.C 61 (a) , defines Gross income means all income from whatever source derived. Question: If gross income ,includes back pay settlements that…
19-435 SIH Partners LLLP, Explorer Corporation v. Commissioner of Internal Revenue Third Circuit 2019-10-02 Denied administrative-law agency-interpretation chevron-deference circuit-split irs-regulation revenue-ruling statutory-interpretation tax-liability tax-regulation The Third Circuit, in conf lict with the D.C., Ninth, and Federal Circuits, deferred to an IRS regulation under step two of Chevron even though the ag…
18-1474 Sunoco, Inc. v. United States Federal Circuit 2019-05-24 Denied Amici (1) congressional-intent excise-tax federal-circuit renewable-fuels statutory-interpretation tax-credits tax-incentives tax-liability tax-system Whether the Federal Circuit properly held that tax credits operate as a reduction of tax liability rather than as a payment of taxes owed.
18-1405 Robert N. Taylor, III v. United States Third Circuit 2019-05-08 Denied Response Waived civil-rights constitutional-rights due-process first-amendment good-faith income-tax standing tax tax-liability waiver waiver-of-rights Whether a citizen who is standing upon his constitutionally protected rights can be compelled, against his good faith understanding of his liability u…
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…
18-1069 Diebold Foundation, Inc., Transferee v. Commissioner of Internal Revenue Second Circuit 2019-02-15 Denied circuit-split commissioner-notice jurisdictional-issue second-circuit statutory-interpretation tax-appeals tax-court-jurisdiction tax-liability tax-notice tax-procedure tax-year taxable-year waiver 1. Whether the Tax Court lacks jurisdiction to consider and determine a liability for an incorrect taxable year when it does not have jurisdiction ove…