tax-treaty

Case	Title	Lower Court	Docketed	Status	Flags	Tags	Question Presented
22-1179	Sabena Puri v. United States	Ninth Circuit	2023-06-06	Denied	Response Waived	abuse-of-process foreign-government-inquiry good-faith irs-summons judicial-process judicial-review powell-framework tax-treaty treaty-request united-states-v-powell united-states-v-stuart	Is a foreign government's abusive or bad faith purpose ever relevant to the enforcement of an IRS summons issued pursuant to a treaty request?
20-1300	Emilio Torres Luque, et al. v. Commissioner of Internal Revenue	Ninth Circuit	2021-03-19	Denied	Response Waived	cross-border-residency double-taxation international-tax-law ninth-circuit reciprocity residency revenue-procedure supremacy-clause tax-treaty treaty-interpretation	This is a case of first impression. There are no similar cases that either party or the Court's own research could find. The Supremacy Clause of Artic…
20-6639	Todd Anthony Aurit v. Colorado	Colorado	2020-12-16	Denied	IFP	detention-authority foreign-estate foreign-person foreign-trust internal-revenue-code non-us-person tax-treaties tax-treaty taxpayer-relief-act	1. Whether the Court should resolve the following questions for which the higher state court denied last resort in this case: does the State of Colora…