| 22-335 |
Richard Collins v. United States |
Third Circuit |
2022-10-11 |
Denied |
Response Waived |
bank-secrecy-act due-process fbar-penalty internal-revenue-service irs proportionality tax-reporting treasury-department willful-failure |
Whether the Government overreached by imposing any penalty on a taxpayer who owed no additional income tax and voluntarily amended his tax return befo… |
| 22-323 |
Oakbrook Land Holdings, LLC, et al. v. Commissioner of Internal Revenue |
Sixth Circuit |
2022-10-06 |
Denied |
Amici (4) |
administrative-procedure-act charitable-donations conservation-easement conservation-easements income-tax-deductions judicial-review proceeds-regulation regulatory-process tax-deduction treasury-department |
Whether Treasury's failure to respond to comments raising concerns about the Proceeds Regulation, 26 C.F.R. § 1.170A-14(g)(6)(ii), violated the Admini… |
| 21-1607 |
Oleg Deripaska v. Janet L. Yellen, Secretary of the Treasury, et al. |
District of Columbia |
2022-06-29 |
Denied |
Response Waived |
administrative-law civil-procedure due-process executive-orders foreign-assets-control international-emergency-economic-powers-act international-law national-emergency national-security sanctions treasury-department |
In 2018, the United States Department of the Treasury's Office of Foreign Assets Control designated Oleg Deripaska under Executive Orders 13661 and 13… |
| 21-82 |
Alpine Securities Corporation v. Securities and Exchange Commission |
Second Circuit |
2021-07-21 |
Denied |
Amici (2) |
administrative-law agency-authority bank-secrecy-act enforcement-authority mens-rea sec-enforcement securities-and-exchange-commission securities-exchange-act statutory-interpretation treasury-department |
In enacting and amending the Bank Secrecy Act (BSA), Congress vested the Secretary of the Treasury with the authority to administer, interpret, and en… |
| 19-1009 |
Altera Corporation & Subsidiaries v. Commissioner of Internal Revenue |
Ninth Circuit |
2020-02-13 |
Denied |
Amici (5) |
administrative-procedure-act arm's-length-standard chevron-deference cost-sharing rulemaking stock-based-compensation tax tax-regulation tax-treaties treasury-department |
1. Whether the Treasury Department's regulation is arbitrary and capricious and thus invalid under the Administrative Procedure Act, 5 U.S.C. 551 et s… |