Whether the income derived from the sale of sand and gravel, mined from treaty-protected land by an enrolled member of the Seneca Nation of Indians, is exempt from federal income tax under the terms of two federal treaties

question presented is whether the United States Court of Appeals and the United States Tax Court have given “due regards” to the treaty obligations of the United States by finding these treaties had no textual support for an exemption from federal income tax applicable to an enrolled Seneca member whose income is derived from the lands of the Seneca Nation. Perkins v. Comm’r, 970 F.3d 148, 162-67 (2d. Cir. 2020).