| 24-455 |
Nnabugwu Eze v. Commissioner of Internal Revenue |
Fourth Circuit |
2024-10-23 |
Denied |
Response Waived |
business-expenses cohen-rule notice-of-deficiency record-keeping statutory-interpretation tax-jurisdiction |
Did the Tax Court lack jurisdiction due to improper notice of deficiency and fail to appropriately apply the Cohen rule for estimating business expens… |
| 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 |
| 21-7875 |
Freya D. Pearson v. United States |
Eighth Circuit |
2022-05-16 |
Denied |
Response WaivedRelisted (2)IFP |
appellate-procedure constitutional-right direct-appeal due-process effective-counsel ineffective-assistance notice-of-deficiency notice-of-withdrawal notice-requirement prosecutorial-misconduct tax-deficiency |
Right To Counsel |
| 19-175 |
Brad S. Francis, et al. v. Commissioner of Internal Revenue |
Eighth Circuit |
2019-08-07 |
Denied |
Response Waived |
administrative-procedure-act agency-misconduct appellate-procedure due-process jurisdiction notice-of-deficiency personal-jurisdiction reasoned-opinion statutory-notice subject-matter-jurisdiction tax-court tax-court-jurisdiction |
Does the Eighth Circuit's judgement and PER CURIAM AFFIRMANCE using Local Rule 47B AFFIRMANCE OR ENFORCEMENT WITHOUT OPINION of Case No. 18-2447 satis… |
| 18-1270 |
Henry M. Jagos, et ux. v. Commissioner of Internal Revenue |
Sixth Circuit |
2019-04-03 |
Denied |
Response Waived |
administrative-law administrative-procedure circuit-court-split circuit-split civil-procedure due-process eighth-circuit judicial-review jurisdiction notice-of-deficiency sixth-circuit standing tax-appeals tax-court tax-court-jurisdiction tax-procedure |
Did the Tax Court lack jurisdiction when it had no facially legitimate notice of deficiency? |