No. 24-885

Rockwater, Inc., dba Peerless Manufacturing Company v. United States

Lower Court: Eleventh Circuit
Docketed: 2025-02-18
Status: Denied
Type: Paid
Response Waived
Tags: design-features federal-excise-tax highway-transportation statutory-exception statutory-interpretation vehicle-classification
Key Terms:
JusticiabilityDoctri
Latest Conference: 2025-03-21
Question Presented (AI Summary)

What is the proper statutory interpretation of 26 U.S.C. § 7701(a)(48)(A)(i) regarding the classification and taxation of specialized vehicles?

Question Presented (OCR Extract)

This statutory interpretation case raises the primary question as to the plain (best) meaning of 26 U.S.C. § 7701(a)(48)(A)(i) and, in the context of the federal excise tax scheme under 26 U.S.C. § 4051(a) , raises these four interrelated issues regarding the test for applying that statutory exception : 1) What role does the ability of a vehicle to transport a load over the highway play in the statutory inquiry under 26 U.S.C. § 7701(a)(48)(A)(i) ? 2) Does the two-prong test under 26 U.S.C. § 7701(a)(48)(A)(i) require comparison of the vehicle in question to a traditional highway vehicle to identify the special design features and impairments or limitations ? 3) Whether the phrase “specially designed for the primary function of transporting a particular type of load other than over the public highway…” as used in 26 U.S.C. § 7701(a)(48)(A)(i) require s consideration of the design elements of the entire vehicle or just particular components of the vehicle ? 4) Does the phrase “substantially limited or impaired” as used in 26 U.S.C. § 7701( a)(48)(A)(i) require consideration of all forms of impairment or limitation ? -iiRULE 14( b) STATEMENT The

Docket Entries

2025-03-24
Petition DENIED.
2025-02-26
DISTRIBUTED for Conference of 3/21/2025.
2025-02-21
Waiver of United States of right to respond submitted.
2025-02-21
Waiver of right of respondent United States to respond filed.
2025-02-13
Petition for a writ of certiorari filed. (Response due March 20, 2025)

Attorneys

Rockwater, Inc. d.b.a. Peerless Manufacturing Co.
David Decoursey AughtryChamberlain, Hrdlicka, et al., Petitioner
David Decoursey AughtryChamberlain, Hrdlicka, et al., Petitioner
United States
Sarah M. HarrisActing Solicitor General, Respondent
Sarah M. HarrisActing Solicitor General, Respondent