tax-penalty
3 cases — ← All topics
| Case | Title | Lower Court | Docketed | Status | Flags | Tags | Question Presented |
|---|---|---|---|---|---|---|---|
| 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… | |
| 21-631 | Emily S. Wilson, as Executrix of the Estate of Joseph A. Wilson, et al. v. United States | Second Circuit | 2021-10-29 | Denied | Response Waived | administrative-law chevron-deference foreign-trust irs-policy irs-reporting statutory-interpretation tax-law tax-penalty | Beginning in 1997, the Internal Revenue Service ("IRS") required the owners of foreign trusts to file an annual Form 3520, disclosing the trust's fina… |
| 20-1697 | Alice Kimble v. United States | Federal Circuit | 2021-06-09 | Denied | Response Waived | 8th-amendment eighth-amendment excessive-fine fbar foreign-bank-account-report statutory-interpretation tax-evasion tax-penalty willful-violation willfulness | 1. Did the Court err in holding that Alice acted willfully, despite the lack of proof either that she had knowledge of the requirement to file an FBAR… |