internal-revenue-service
16 cases — ← All topics
| Case | Title | Lower Court | Docketed | Status | Flags | Tags | Question Presented |
|---|---|---|---|---|---|---|---|
| 25A435 | The Society of Apostolic Church Ministries Bishop, Elizabeth Gardner Corporation Sole and Her Successors v. United States | Ninth Circuit | 2025-10-16 | Presumed Complete | internal-revenue-service nominee-theory property-rights religious-organization tax-levy tax-lien | 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 taxpa… | |
| 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… |
| 24-715 | Thomas Shands v. Commissioner of Internal Revenue | District of Columbia | 2025-01-03 | Denied | Response Waived | internal-revenue-service judicial-review statutory-interpretation subject-matter-jurisdiction tax-court whistleblower-award | Whether the IRS can deprive the United States Tax Court of subject matter jurisdiction by claiming it took no action on a whistleblower award and deny… |
| 24-416 | Commissioner of Internal Revenue v. Jennifer Zuch | Third Circuit | 2024-10-15 | Judgment Issued | Amici (4) | administrative-review internal-revenue-service jurisdictional-challenge pre-deprivation-proceeding tax-court tax-levy | Whether a pre-levy proceeding under 26 U.S.C. 6330 becomes moot when there is no longer a live dispute over the proposed levy |
| 23-1037 | Commissioner of Internal Revenue v. Isobel Berry Culp, et vir | Third Circuit | 2024-03-19 | Denied | 26-usc-6213 internal-revenue-service judicial-review petition-timeliness statutory-interpretation tax-assessment tax-court-jurisdiction tax-deficiency tax-procedure untimely-petition | Whether 26 U.S.C. 6213(a) grants the Tax Court jurisdiction to review an untimely petition for redetermination of a tax deficiency? | |
| 23-6145 | Daniel E. Salley v. United States | Seventh Circuit | 2023-12-01 | Denied | Response WaivedIFP | civil-rights criminal-procedure due-process internal-revenue-service mental-competency mental-health-defense property-rights property-seizure statute-of-limitations tax-law treasury-offset-program | Whether a college graduate and successful businessman owner of a small accounting firm, who prevailed in several audits at the Internal Revenue Servic… |
| 23-413 | Michael Lissack v. Commissioner of Internal Revenue | District of Columbia | 2023-10-19 | GVR | Relisted (2) | administrative-action administrative-law agency-discretion chevron-deference discretion internal-revenue-service statutory-interpretation tax-law tax-whistleblower whistleblower-award | Whether the IRS is required to pay a whistleblower award where the whistleblower's information caused the IRS to open an audit but the IRS ultimately … |
| 22-1232 | Bernard D. Holland v. Commissioner of Internal Revenue | Fourth Circuit | 2023-06-23 | Denied | Response WaivedRelisted (2) | civil-procedure constitutional-authority constitutional-law direct-taxation due-process form-4852 internal-revenue-service irs-authority standing tax-law | Is the IRS required to follow the Constitution and tax laws? |
| 22-7817 | Garland E. Williams v. United States | Federal Circuit | 2023-06-20 | Denied | Response WaivedIFP | civil-procedure civil-rights due-process internal-revenue-service jurisdictional-challenge standing statutory-interpretation takings takings-clause tax tax-refund | Whether claimed pursuant 28 U.S.C. § 1491 (a) (1) United States Constitutional Article II, Section 2, Amendment J, due-process, takings, 26-usc-6402 |
| 22-6631 | Larry Welenc v. Commissioner of Internal Revenue | District of Columbia | 2023-01-25 | Denied | Response WaivedIFP | administrative-law administrative-procedure due-process internal-revenue-service irs notice-of-intent property-rights property-seizure seizure tax-law tax-levy taxpayer-rights | Can the Commissioner of the Internal Revenue Service issue a NON Final Intent of Notice for immediate payment of Amount Due, to be paid within a deadl… |
| 22-508 | John O. Green v. United States | Fifth Circuit | 2022-11-30 | Denied | Response Waived | 18-usc-371 conspiracy conspiracy-to-defraud criminal-law criminal-prosecution defraud-the-united-states federal-agency internal-revenue-service jury-instructions statutory-interpretation | Whether a trial court in a conspiracy to defraud prosecution premised on 18 U.S.C. § 371 must instruct the trial jury about the functions of the agenc… |
| 22-335 | Richard Collins v. United States | Third Circuit | 2022-10-11 | Denied | Response Waived | bank-secrecy-act due-process fbar-penalty internal-revenue-service irs proportionality tax-reporting treasury-department willful-failure | Whether the Government overreached by imposing any penalty on a taxpayer who owed no additional income tax and voluntarily amended his tax return befo… |
| 22-291 | Brian H. McLane v. Commissioner of Internal Revenue | Fourth Circuit | 2022-09-27 | Denied | Amici (1)Response Waived | appeals-hearing internal-revenue-service notice-of-deficiency overpayment-determination tax-appeals tax-collection tax-court tax-court-jurisdiction tax-liability tax-overpayment | Whether the Tax Court has jurisdiction to determine the amount of any overpayment due a taxpayer who never received a notice of deficiency |
| 22-185 | Mandy Mobley Li v. Commissioner of Internal Revenue | District of Columbia | 2022-08-30 | Denied | Response Waived | administrative-procedure-act agency-action circuit-split internal-revenue-service judicial-review statutory-interpretation tax-court-jurisdiction tax-relief-and-health-care-act-of-2006 united-states-tax-court whistleblower-award | Whether threshold rejections of whistleblower award requests are immune from the judicial review process established through the Administrative Proced… |
| 20-215 | Richard Bernholz v. Internal Revenue Service | Second Circuit | 2020-08-25 | Denied | Response Waived | federal-tort-claims-act government-liability immunity internal-revenue-service sovereign-immunity statutory-interpretation tax-assessment tax-collection | Whether the Internal Revenue Service's conduct falls within the tax assessment and collection exception to the Federal Tort Claims Act's waiver of imm… |
| 18-1100 | Wayne D. Ramsay v. Commissioner of Internal Revenue | Fifth Circuit | 2019-02-22 | Denied | Response Waived | administrative-law administrative-procedure deficiency deficiency-interest interest internal-revenue-service jurisdiction statutory-interpretation tax tax-court tax-law | Does the U.S. Tax Court have jurisdiction to determine deficiency interest assessed by the Internal Revenue Service? |