No. 25-177

Vito Manente v. Commissioner of Internal Revenue

Lower Court: Third Circuit
Docketed: 2025-08-14
Status: Denied
Type: Paid
Response Waived
Tags: constitutional-interpretation direct-taxation internal-revenue labor-taxation sixteenth-amendment sovereign-person
Key Terms:
Securities
Latest Conference: 2025-09-29
Question Presented (AI Summary)

Whether the Sixteenth Amendment negates constitutional provisions on direct taxation and applies to sovereign persons' labor taxation

Question Presented (OCR Extract)

The U.S. Const., art. 1, sec. 2, cl. 3 states that “Representatives and direct Taxes shall be apportioned among the several States ...” The U.S. Const., art. 1, sec. 9, cl. 4 states that “No capitation, or other direct, tax shall be laid, unless in proportion to the census or enumeration herein before directed to be taken. ” The Questions Presented are: 1. Has the Sixteenth Amendment negated U.S. Const., art. 1, sec. 2, cl. 3 and U.S. Const, art. 1, sec. 9, cl. 4 by allowing taxation on a sovereign person ’s labor and to clarify not wages as divined in the Internal Revenue Code (26 U.S. Code § 3401(c))? 2. Do the Sixteenth Amendment and 26 U.S.C. § 7701(a)(9)-(10) apply to the Constitutional fifty States of the Union or to the Statutory District of Columbia and the territories thereof (e.g. Guam)? 11 LIST OF PROCEEDINGS U.S. Court of Appeals for the Third Circuit No. 24-2548 Vito Manente, Appellant, v. Commissioner of Internal Revenue Final Opinion: April 9, 2025 Rehearing Denial: May 27, 2025 U.S. Tax Court No. 1013-23 In the Matter of: Vito Manente, Petitioner, v. Commissioner of Internal Revenue, Respondent. Final Opinion: April 9, 2024

Docket Entries

2025-10-06
Petition DENIED.
2025-08-20
DISTRIBUTED for Conference of 9/29/2025.
2025-08-18
Waiver of Respondent of right to respond submitted.
2025-08-18
Waiver of right of respondent Respondent to respond filed.
2025-06-09
Petition for a writ of certiorari filed. (Response due September 15, 2025)

Attorneys

Respondent
D. John SauerSolicitor General, Respondent
Vito Manente
Vito Manente — Petitioner