Whether the IRS may impose a tax lien and levy on a religious organization's property based on the theory that the organization is a nominee for taxpayers who have failed to pay their income taxes

No question identified. : 1. On July 24, 2025, the United States Court of Appeals for the Ninth Circuit affirmed Society of Apostolic Church Ministries Bishop v. U.S., No. 24-1765, 2025 WL 2083124 (9th Cir. 2025) in a two to one split. A copy of the decision is attached hereto as Exhibit A. 2. The U.S. District Court for the District of Arizona also entered an Order upon motion for consideration at Society of Apostolic Church Ministries, et al. v. U.S., No. 2024 WL 2942707 (D. Ariz. June 11, 2024), a copy of which is attached hereto as Exhibit B. 3. The Petitioner has had financial difficulties in raising funds for the Writ of Certiorari, and appellate counsel will need sufficient time to fully evaluate the merits of this matter and file the Petition for a Writ of Certiorari. 4, Also, this request is made due to the lower court having made significant legal mistakes that affected the outcome of the case. The case may involve important questions of law or public interest that warrant Supreme Court reviews. The legal error was that the court failed to consider the facts in a light favorable to the non-moving party. It is important because of the underlying animus of the lower courts towards Christian religious organizations which has resulted in a denial of sovereignty of the church organization. WHEREFORE, Petitioner respectfully requests that the Court grant this Application for an Extension of Time to File the Petition for Writ of Certiorari to December 22, 2025. DATED this 9 day of October 2025. RESPECTFULLY SUBMITTED, /s/ Dennis I. Wilenchik Dennis I. Wilenchik, Esq. WILENCHIK & BARTNESS The Wilenchik & Bartness Building 2810 North Third Street Phoenix, Arizona 85004 602-606-2810 admin@wb-law.com Attorney for Petitioner EXHIBIT A WILENGHIK & BARTNESS A PROFESSIONAL CORPORATION Society of Apostolic Church Ministries Bishop v. United States, Not Reported in Fed. 136 A.F.T.R.2d 2025-5303 2025 WL 2083124 United States Court of Appeals, Ninth Circuit. The SOCIETY OF APOSTOLIC CHURCH MINISTRIES BISHOP, Elizabeth Gardner Corporation Sole and Her Successors, Plaintiff Appellant, v. UNITED STATES of America, Defendant Appellee. No. 24-1765 | Argued and Submitted May 12, 2025 Phoenix, Arizona | FILED JULY 24, 2025 Appeal from the United States District Court for the District of Arizona, Diane J. Humetewa, District Judge, Presiding, D.C. No. 3:21-cv-08277-DJH Attorneys and Law Firms Gregory A. Robinson, Farley, Robinson & Larsen, Phoenix, AZ, for Plaintiff Appellant The Society of Apostolic Church Ministries Bishop, Elizabeth Gardner Corporation Sole and Her Successors. Elizabeth Gardner, Dewey, AZ, for Plaintiff Appellant Elizabeth Gardner. Douglas Campbell Rennie, Jennifer Marie Rubin, Amy Talburt Matchison, DOJ U.S. Department of Justice, Tax Division, Washington, DC, for Defendant Appellee. Before: RAWLINSON, BUMATAY, and SANCHEZ, Circuit Judges. MEMORANDUM ~ *1 Plaintiff Society of Apostolic Church Ministries Bishop (“the Society”) brought this suit against Defendant United States challenging the Internal Revenue Service's (“IRS”) tax lien on the Society's Apache Knolls property and levy on the Society's bank account to recover $826,381.05 in unpaid taxes owed by Elizabeth and Frederic Gardner for tax years 2002 through 2004. This action reflects another entry in a decadeslong effort by the Gardners to avoid paying income taxes— an effort that has already reached this court four times. I WESTLAW The IRS' tax lien and levy proceeded under the theory that the Society is the Gardners' “nominee.” A “nominee” is “one who holds bare legal title to property for the benefit of another.” Fourth Inv. LP v. United States, 720 F.3d 1058, 1066 (9th Cir. 2013) (citation omitted). We review the district court's grant of summary judgment for the Government de novo, considering the evidence in the light most favorable to the Society and drawing all reasonable inferences in its favor as the nonmoving party. See Hittle v. City of Stockton, 101