No. 25-7145

Lori Michelle Patitz, nka Lori Michelle Moody v. Commissioner of Internal Revenue

Lower Court: Eleventh Circuit
Docketed: 2026-04-06
Status: Pending
Type: IFP
Response WaivedIFP
Tags: deductions internal-revenue-service statutory-interpretation tax-collection tax-court treasury-regulations
Latest Conference: 2026-05-01
Question Presented (from Petition)

1. Does the Internal Revenue Service
have the right to collect taxes from
citizens that are not legally owed?

2. Can the Tax Court levy taxes and
penalties against taxpayers despite
the fact that they have provided
substantiation for their deductions
in compliance with the Treasury
Rules and Regulations?

3. Are Courts confined to interpreting
Treasury Rules and Regulations
according to the literal meaning of
the words employed?

Question Presented (AI Summary)

Whether the Internal Revenue Service may collect taxes not legally owed and whether Tax Court may levy taxes and penalties against taxpayers who have provided substantiation for deductions in compliance with Treasury Rules and Regulations, and whether courts are confined to interpreting Treasury Rules and Regulations according to the literal meaning of the words employed

Docket Entries

2026-04-16
DISTRIBUTED for Conference of 5/1/2026.
2026-04-08
Waiver of CIR of right to respond submitted.
2026-04-08
Waiver of right of respondent CIR to respond filed.
2025-09-23
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due May 6, 2026)

Attorneys

CIR
D. John SauerSolicitor General, Respondent
Lori Michelle Patitz
Lori Michelle Patitz — Petitioner