irs

33 cases — ← All topics

Case Title Lower Court Docketed Status Flags Tags Question Presented
23-957 David Michael Bishop, et al. v. United States, et al. Tenth Circuit 2024-03-04 Denied Response Waived administrative-investigation civil-rights due-process first-amendment free-speech irs irs-summons judicial-review powell-factors standing tax tax-procedure Whether the IRS summons process is subject to quashing and constraint by the First Amendment's protections against chilling or retaliatory government …
23-653 Ritchie N. Stevens, et al. v. Commissioner of Internal Revenue Ninth Circuit 2023-12-15 Denied Response Waived civil-procedure irs net-operating-loss partnership partnership-audit tax tax-court tax-law tefra tefra-regime unsigned-returns Whether a net operating loss carryover to a future year that is an 'affected item' under the TEFRA Partnership audit regime can be included within the…
23-614 Rocky Branch Timberlands LLC v. United States, et al. Eleventh Circuit 2023-12-07 Denied Response Waived anti-injunction-act civil-procedure due-process irs iRS-procedure judicial-review tax-assessment tax-collection taxpayer-rights Whether the Anti-Injunction Act's bar on lawsuits for the purpose of restraining the assessment or collection of taxes also bars courts from enforcing…
23-436 Vikki E. Paulson, et al. v. United States Ninth Circuit 2023-10-26 Denied beneficiaries estate-taxes government-collection internal-revenue-code irs personal-liability tax-lien transferee-liability transferees trustees Does 26 U.S.C. § 6324(a)(2) allow the Government to impose personal liability on transferees, trustees or beneficiaries who receive property from the …
22-6797 Dominick Galluzzo v. Internal Revenue Service Third Circuit 2023-02-16 Denied Response WaivedRelisted (2)IFP attorney-misconduct bankruptcy bankruptcy-procedure irs iRS-assessment judicial-misconduct proof-of-claim tax-court tax-dispute venue venue-selection Was the petitioner mis-represented at bankruptcy by their attorney not asking for attachments to PROOF OF CLAIM according to rule 3001 and B10 (exhibi…
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…
22-6456 Paul D. Weldon v. United States Ninth Circuit 2023-01-04 Denied Response WaivedIFP 14th-amendment attorney-general-authorization due-process irs jurisdictional-challenge tax-assessment tax-collection third-party-filing third-party-filings Whether the IRS violated the petitioner's procedural due process rights in the tax collection and assessment process
22-598 Arthur Bedrosian v. United States, et al. Third Circuit 2022-12-29 Denied Amici (1)Response RequestedResponse WaivedRelisted (2) civil-penalty civil-procedure due-process foreign-account foreign-account-reporting irs objective-standard statutory-interpretation subjective-standard tax willful-violation willfulness Whether willfulness under 31 U.S.C. § 5321(a)(5)(C) should be determined according to a subjective, rather than objective, standard that focuses on an…
22-473 Hancock County Land Acquisitions, LLC v. United States, et al. Eleventh Circuit 2022-11-18 Denied Response Waived anti-injunction-act civil-procedure due-process irs iRS-procedure judicial-review tax-assessment tax-collection tax-law taxpayer-rights Whether the Anti-Injunction Act's bar on lawsuits for the purpose of restraining the assessment or collect of taxes also bars courts from enforcing la…
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…
22-114 Mark Anthony Blommer v. Commissioner of Internal Revenue Ninth Circuit 2022-08-08 Denied Response Waived administrative-law due-process irs irs-procedure non-statutory-notices statutory-compliance substitute-return substitutes-for-return tax-deficiency taxpayer-rights Whether a notice of deficiency must comply with applicable statutes to be valid
21-1599 Hanna Karcho Polselli, et al. v. Internal Revenue Service Sixth Circuit 2022-06-28 Judgment Issued Amici (6)Relisted (2) collection delinquent-taxpayer irc-section-7609 irs judicial-review notice-requirement recordkeeper-exception standing summons summons-notice tax-law Whether the § 7609(c)(2)(D)(i) exception to the IRS summons notice requirement applies only when the summonsed records belong to the delinquent taxpay…
21-6483 Robert A. McNeil v. Department of State, et al. District of Columbia 2021-12-02 Denied Response WaivedIFP administrative-procedure appellate-jurisdiction civil-procedure due-process irs judicial-review passport-revocation standing tax tax-law Do courts of appeal nationwide exhibit a pattern and practice of refusing to adjudicate EVERY issue presented by the Class of disrespected, unrepresen…
21-628 Ebenezer K. Howe, IV v. United States Ninth Circuit 2021-11-01 Denied Response WaivedRelisted (2) access-to-courts civil-rights court-of-appeals due-process irs judicial-impartiality judicial-independence judicial-misconduct pro-se-litigant recusal Do courts of appeal exhibit a pattern and practice of refusing to adjudicate EVERY ISSUE presented by the Class of disrespected, unrepresented litigan…
21-601 Michael B. Ellis, et al. v. Amy Berman Jackson, et al. District of Columbia 2021-10-26 Denied Response Waived anti-injunction-act appellate-procedure civil-procedure civil-rights constitutional-challenge due-process irs judicial-review pro-se-litigation record-falsification standing Do courts of appeal nationwide exhibit a pattern and practice of refusing to adjudicate EVERY issue presented by the Class of disrespected, unrepresen…
21-237 James Clay, et al. v. Commissioner of Internal Revenue Eleventh Circuit 2021-08-18 Denied Response Waived 25-usc-2 bureau-of-indian-affairs federal-regulations indian-tribe irs land-compensation secretary-of-interior tax-interpretation tribal-lands tribal-sovereignty Whether the clear language of Title 25 of the Code of Federal Regulations, and the exclusive authority over federally recognized Indian Tribes granted…
20-1344 Jeffrey T. Maehr v. United States Tenth Circuit 2021-03-24 Denied Response Waived 16th-amendment civil-rights constitutional-interpretation due-process income-definition irs standing stare-decisis supreme-court-precedent tax-law taxation Can the IRS/United States consistently call U.S. Supreme Court standing case precedent (stare decisis) on the definition of income, as 'legally frivol…
20-1129 Scott Phillip Flynn v. United States Eighth Circuit 2021-02-17 Denied Amici (1) constitutional-rights criminal-procedure due-process guilty-plea irs jury-trial klein-conspiracy restitution seventh-amendment sixth-amendment Whether the due process clause requires discussion of the elements of an 18 U.S.C. § 371 conspiracy to defraud the IRS before accepting a guilty plea
20-681 Daniel E. Larkin, et ux. v. Commissioner of Internal Revenue District of Columbia 2020-11-17 Denied Response Waived burden-of-production burden-of-proof civil-procedure irs irs-restructuring judicial-review penalties statutory-interpretation supervisory-approval tax-law tax-penalties Does the Internal Revenue Service Restructuring and Reform Act of 1998 require the Secretary of the Treasury to come forward with evidence of written …
20-514 Edward F. Sadjadi, et ux. v. Commissioner of Internal Revenue Fifth Circuit 2020-10-19 Denied Response Waived contingent-obligations contract-interpretation debt-repayment irs irs-agreement offer-in-compromise payment-terms statutory-obligation tax-compliance tax-payments Whether the Offer in Compromise (OIC) form contains clear and unambiguous language regarding the obligation to comply with tax payments for the next f…
20-460 Richard E. Boggs v. United States Fourth Circuit 2020-10-09 Denied Response Waived 5th-amendment administrative-determination due-process fifth-amendment irs property-seizure tax-liability withholding-certificate Did the IRS deprive the petitioner of his Constitutional Fifth Amendment right to due process?
19-929 Louis S. Shuman, et ux. v. Commissioner of Internal Revenue Fourth Circuit 2020-01-24 Denied Response WaivedRelisted (2) 5th-amendment administrative-procedure civil-procedure due-process internal-revenue-code irs judicial-review standing tax tax-law Whether the IRS and lower Courts application of IRC 6214(b) and IRC 6402 violate the Due Process Clause of the 5th Amendment
19-7399 Frederick Charles Harris, II v. United States Federal Circuit 2020-01-24 Denied Response WaivedIFP administrative-law asset-seizure civil-procedure due-process irs jurisdiction tax-law Why was my demand denied when the defendant, the Commissioner of the IRS, admitted in writing that they didn't have jurisdiction to take my assets?
19-644 Melba L. Ford v. United States Ninth Circuit 2019-11-19 Denied Response Waived anomalies civil-forfeiture constitutional-rights doj due-process irs judicial-review legal-assistance right-to-counsel standing Does a defendant in an IRS/DoJ civil forfeiture proceeding have a constitutionally protected, due process right to counsel?
19-6481 Harold B. Rotte v. United States Eleventh Circuit 2019-11-04 Rehearing Response WaivedRelisted (2)IFP administrative-law civil-rights due-process equal-protection government-misconduct illegal-immigration irs judicial-review reputation standing tax tax-dispute Whether the laws protect Plaintiffs reputation, due process, and are real, or a front, discretionary as if friend or foe
19-576 Interior Glass Systems, Inc. v. United States Ninth Circuit 2019-11-01 Denied Response Waived administrative-hearing due-process hearing irs iRS-collection penalties seizure statutory-interpretation tax tax-penalties vagueness vagueness-doctrine Is the collection of tax penalties an exception to the requirements of due process, or does a citizen have a right to a hearing before the IRS seizes …
18-1457 Joseph Allen May v. United States, et al. Eighth Circuit 2019-05-22 Denied Response Waived 26-usc-7431 civil-rights discovery discovery-denial-authority discovery-rights due-process federal-courts irs irs-disclosure perpetrator-liability standing tax-law taxpayer-information title-26 Under what authority do the Federal Courts deny Discovery when the IRS and IRS officers have all of the documents and the United States' employees wer…
18-1402 Harold R. Stanley, et al. v. United States District Court for the District of Columbia District of Columbia 2019-05-07 Denied Response Waived appellate-procedure appellate-procedure,filing-fees,refunds Can Circuits impose a burden to prove circumstance Can litigants present their case to appellate cour court-administration court-discretion due-process due-process,mandamus,judicial-misconduct,irs,recor irs judicial-misconduct mandamus mandamus-relief pacer,appellate-procedure,records-on-appeal procedural-due-process record-falsification rule-59-motion supervisory-powers When a judge refuses to adjudicate a Rule 59(e) motion alleging misconduct, can mandamus relief be conditioned on proving the refusal itself is 'egreg…
18-1122 Alpenglow Botanicals, LLC, et al. v. United States Tenth Circuit 2019-02-27 Denied Response RequestedResponse WaivedRelisted (2) 26-usc-280e administrative-determination administrative-determinations administrative-law civil-rights criminal-culpability criminal-law criminal-penalties drug-crimes drug-trafficking due-process irs irs-investigation section-280e standing tax tax-deductions tax-law Taxpayer's challenge to IRS authority to investigate federal drug law crimes and administratively determine criminal culpability under 26 U.S.C. §280E…
18-6922 Raghvendra Singh v. Wells Fargo Bank, N.A. Ninth Circuit 2018-12-07 Dismissed Response WaivedIFP anti-deficiency-statutes civil-procedure constitutional-rights foreclosure form-1099 irs non-recourse-debt tax-code tax-hardship wells-fargo-bank Is the Form 1099 illegal for non-recourse debt?
18-554 Charles J. Weiss v. Commissioner of Internal Revenue District of Columbia 2018-10-29 Denied Response Waived administrative-law due-process irs levy-action notice statutory-interpretation tax tax-notice taxpayer-rights Whether the IRS notice means what it says - that the 30 days runs from 'the date of this letter,' or whether it means the 30 days runs from the date o…
18-6128 Norman Douglas Diamond v. Commissioner of Internal Revenue District of Columbia 2018-09-28 Denied Response WaivedRelisted (2)IFP due-process fraud irs irs-corruption jurisdiction jurisdictional-notice overpayment-refund statutory-guarantee statutory-notice tax tax-court tax-court-jurisdiction tax-deficiency tax-evasion tax-fraud When statutes guarantee deficiency proceedings and mandate issuance of notices, do statutes confer jurisdiction and due process even without complianc…
18-6094 Edgar Leopoldo Garcia-Martinez v. United States Tenth Circuit 2018-09-25 Denied Response WaivedIFP brady-disclosure brady-v-maryland confidential-informant dea discovery drug-conspiracy due-process expert-testimony false-swearing irs prosecutorial-misconduct ssa Is the prosecution required to supply information concerning the failure to report income to the IRS and the SSA by the DEA and its confidential infor…