income-tax

18 cases — ← All topics

Case Title Lower Court Docketed Status Flags Tags Question Presented
25-28 Claude Franklin Sanders v. Commissioner of Internal Revenue Sixth Circuit 2025-07-09 Denied Response Waived administrative-procedure-act agency-filing federal-register income-tax jurisdiction tax-court Is the IRS required to publish in the Federal Register the places where federal income tax returns are to be filed, and are citizens subject to income…
24-1317 Brian D. Swanson v. Commissioner of Internal Revenue Eleventh Circuit 2025-06-26 Denied Response Waived employer-liability income-tax internal-revenue-service perjury tax-code tax-determination Does the Tax Code authorize the employer to determine the employee's income tax liability without consent and may the Commissioner of Internal Revenue…
24-7258 In Re Paul Kenneth Cromar 2025-05-21 Denied IFP 16th-amendment constitutional-authority federal-district-court income-tax non-apportioned-tax subject-matter-jurisdiction Does the federal district court possess subject-matter jurisdiction to conduct tax trials and enforce IRS assessments of a non-apportioned direct tax …
24-659 Brian D. Swanson v. Commissioner of Internal Revenue Eleventh Circuit 2024-12-18 Denied Response WaivedRelisted (2) administrative-law constitutional-interpretation income-tax tax-deficiency territory-clause uniformity-clause Did Puerto Rico become an incorporated Territory subject to the Uniformity Clause for federal income tax collection, and did the Commissioner of Inter…
23-903 David E. Stone, et al. v. Commissioner of Internal Revenue Eleventh Circuit 2024-02-21 Denied Response Waived administrative-procedure-act bundled-mortgages executive-branch executive-branch-discretion income-tax internal-revenue-code mortgage-taxation sovereign-immunity tax-collection Whether the Commissioner has absolute discretion and sovereign immunity to decline to collect income taxes on bundled mortgages
23-361 Brian D. Swanson v. United States Eleventh Circuit 2023-10-04 Denied Response Waived constitutional-interpretation federal-appellate-procedure frivolous-sanction income-tax insular-cases puerto-rico territorial-status uniformity-clause unincorporated-territory Has Puerto Rico become an incorporated Territory and become fully subject to the Constitution's Uniformity Clause when collecting the Federal Income T…
22-800 Charles G. Moore, et ux. v. United States Ninth Circuit 2023-02-23 Judgment Issued Amici (51)Relisted (2) apportionment apportionment-requirement article-i congress-power congressional-taxation constitutional-interpretation income-tax realization realization-doctrine sixteenth-amendment Whether the Sixteenth Amendment authorizes Congress to tax unrealized sums without apportionment among the states
21-624 Brian D. Swanson v. Commissioner of Internal Revenue Eleventh Circuit 2021-10-28 Denied Response Waived 11th-circuit circuit-court commissioner direct-tax frivolous income-tax internal-revenue supreme-court supreme-court-precedent tax taxable-income May the Commissioner of Internal Revenue collect a uniform direct tax on Petitioner's taxable income?
19-973 Brian D. Swanson v. United States Eleventh Circuit 2020-02-04 Denied Response Waived apportionment capital capital-tax constitutional-taxation direct-tax federal-tax-return income-classification income-tax rule-12(b)(6) tax-refund May the Respondent collect a direct tax on Petitioner's capital without going through the rule of apportionment?
19-954 Brian E. Harriss v. Commissioner of Internal Revenue Ninth Circuit 2020-01-30 Denied Response Waived amendment-xvi civil-rights constitutional constitutional-interpretation direct-taxation due-process income-tax ninth-circuit standing statutory tax tax-law Whether the Ninth Circuit erred in recharacterizing the petitioner's right to refute the presumptive evidence of the Commissioner's correctness
19-6681 Louis Milton Willis v. Territory of the Virgin Islands Virgin Islands 2019-11-19 Denied IFP 48-usc-1612 district-court exclusive-jurisdiction gross-receipts-tax income-tax organic-act revised-organic-act statutory-interpretation territorial-jurisdiction virgin-islands Whether the plain language of § 22 of the Revised Organic Act of 1954 vests exclusive jurisdiction over gross receipts taxes in the District Court of …
19-366 Walter C. Lange v. Commissioner of Internal Revenue Fifth Circuit 2019-09-19 Denied Response Waived due-process eighth-amendment excise fifth-amendment first-amendment income-tax indirect-tax tax-code title-26 vagueness Whether the income tax under Title 26 of the U.S. Code is an indirect tax and therefore exclusively an excise, duty or impost arising from the exercis…
19-119 Staples, Inc., et al. v. Comptroller of the Treasury of Maryland Maryland 2019-07-24 Denied Response RequestedResponse WaivedRelisted (2) apportionment commerce-clause constitutional-taxation due-process franchise-fees income-apportionment income-tax interstate-commerce royalty royalty-fees royalty-income state-courts state-taxation When an out-of-State business receives royalty fees, franchise fees, or similar payments from in-State businesses, may a State imposing income taxes c…
18-1485 Michael Kansler, et ux. v. Mississippi Department of Revenue Mississippi 2019-05-29 Denied Response Waived commerce-clause double-taxation due-process income-tax internal-consistency internal-consistency-test interstate-commerce residency state-tax-law state-taxation statute-of-limitations tax-statute-of-limitations Whether Mississippi's income tax refund statute of limitation is immune from Commerce Clause scrutiny under Complete Auto Transit and the internal con…
18-1405 Robert N. Taylor, III v. United States Third Circuit 2019-05-08 Denied Response Waived civil-rights constitutional-rights due-process first-amendment good-faith income-tax standing tax tax-liability waiver waiver-of-rights Whether a citizen can be compelled to waive constitutional rights or pay a tax he does not owe in good faith
18-7887 Rodney Lyle Roberts v. United States Fifth Circuit 2019-02-11 Denied Response WaivedIFP 16th-amendment apportionment brushaber-case constitutional-basis constitutional-interpretation direct-income-tax direct-tax fifth-circuit-precedent income-tax parker-v-commissioner precedent sixteenth-amendment tax tax-law Whether the Fifth Circuit precedent in Parker v. Commissioner becomes unassailable in holding that the Sixteenth Amendment provided the needed constit…
18-664 Cynthia Bauerly, Commissioner, Minnesota Department of Revenue v. William Fielding, Trustee of the Reid and Ann MacDonald Irrevocable GST Trust for Maria V. MacDonald, et al. Minnesota 2018-11-21 Denied Relisted (2) conflict-of-laws constitutional-law due-process family-business income-tax income-taxation resident-trust resident-trusts state-taxation trustee-location Does the Due Process Clause prohibit states from imposing incomes taxes on statutory 'resident trusts' that have significant additional contacts with …
18-5353 Juanita L. Berry v. United States Third Circuit 2018-07-25 Denied Response WaivedIFP civil-procedure court-of-appeals district-court due-process income-classification income-tax irs-regulations loans loss-calculation promissory-notes property-rights tax tax-evasion tax-law wire-fraud Whether the Court of Appeals erred in affirming the District Court's legal holding that promissory notes between Berry and a vendor were income and no…