| 25-719 |
Stanley Battat, et ux. v. Commissioner of Internal Revenue |
Eleventh Circuit |
2025-12-18 |
Pending |
|
administrative-procedure initial-determination irc-section-6751 managerial-approval tax-assessment tax-penalty |
Internal Revenue Code Section 6751(b)(1) provides that "[n]o penalty under this title shall be assessed unless the initial determination of such asses… |
| 25-205 |
Schuyler E. Cole, et al. v. City and County of Honolulu, Hawaii |
Hawaii |
2025-08-20 |
Denied |
Response Waived |
constitutional-law equal-protection fourteenth-amendment property-valuation tax-assessment tax-classification |
Whether a real property tax class that consists of certain residential properties that are distinguished from identical residential properties based s… |
| 24-238 |
Charles K. Breland, Jr. v. Commissioner of Internal Revenue |
Eleventh Circuit |
2024-09-03 |
Denied |
Response Waived |
bankruptcy-court consent-order iRS-claims res-judicata tax-assessment tax-liability |
Whether a bankruptcy court's consent order limiting the IRS's tax collection rights is binding and preclusive in subsequent tax court proceedings |
| 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? |
| 23-762 |
Sam Silverberg v. District of Columbia, et al. |
District of Columbia |
2024-01-17 |
Denied |
Response Waived |
appellate-discretion constitutional-challenge constitutional-challenges exclusive-jurisdiction federal-jurisdiction property-rights state-revenues subject-matter-jurisdiction tax-assessment tax-assessments |
Whether the exclusive jurisdiction to shield local tax assessments from constitutional challenges in a federal court to protect state revenues can be … |
| 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… |
| 23-443 |
MMN Infrastructure Services, LLC, Successor in Interest to Vectren Infrastructure Services Corp. v. Michigan Department of Treasury |
Michigan |
2023-10-27 |
Denied |
Amici (3)Response Waived |
corporate-disclosure extraterritorial-taxation factor-representation fair-apportionment interstate-commerce short-tax-year tax-apportionment tax-assessment temporal-element |
Whether a state must include in its tax apportionment formula the factors of a business giving rise to income to be taxed, and whether factor represen… |
| 23-5703 |
Festus Okwudili Ohan v. ABN AMRO, et al. |
Ninth Circuit |
2023-10-03 |
Denied |
Relisted (2)IFP |
civil-liberties civil-rights conspiracy constitutional-rights due-process judicial-procedure legal-interpretation property property-rights takings tax-assessment |
Whether the petitioner's due process rights were violated when the district attorney, court, and tax assessors conspired to deprive the petitioner of … |
| 23-233 |
Antero Resources Corporation v. Matthew R. Irby, West Virginia Tax Commissioner, et al. |
West Virginia |
2023-09-13 |
Denied |
Response Waived |
dormant-commerce-clause in-state-sellers interstate-commerce natural-gas out-of-state-sellers post-production-expenses property-tax tax-assessment |
Whether West Virginia's refusal to allow natural gas producers to deduct actual post-production expenses for property tax purposes, which favors in-st… |
| 22-6692 |
Jerez Coleman v. Maryland |
Maryland |
2023-02-02 |
Denied |
IFP |
administrative-review civil-rights constitutional-rights due-process equal-protection procedural-burden property-rights property-tax takings tax-assessment tax-sale |
Whether the petitioner's appearance at a tax sale violates the Fourteenth Amendment's due process and equal protection clauses |
| 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 |
| 22-473 |
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… |
| 22-5386 |
Pamela Bond v. McKean County, Pennsylvania |
Third Circuit |
2022-08-18 |
Denied |
Response WaivedIFP |
civil-rights due-process judicial-interpretation pennsylvania-law property property-tax real-estate real-estate-law tax-assessment tax-delinquency taxation vehicle-transfer |
Whether the 2005 Dodge Caravan was properly registered and inspected, whether Pennsylvania rebate laws apply to the property taxes on 316 Dawson Stree… |
| 21-1457 |
Quiller Barnes v. Commissioner of Internal Revenue |
Ninth Circuit |
2022-05-18 |
Denied |
Response Waived |
due-process internal-revenue-regulations irs-regulations pension-funds pension-rollover retirement-funds rollover statute-of-limitations tax-assessment tax-law |
Whether the petitioner's 1996 pension funds were properly rolled over and should not have been taxed |
| 20-1583 |
Jeffrey Olson v. Minnesota Commissioner of Revenue |
Minnesota |
2021-05-14 |
Denied |
Response Waived |
administrative-procedure appeal commissioner-order commissioner's-order due-process mail-notice ordinary-mail procedural-due-process tax-appeal tax-assessment tax-procedure |
Whether issuance of a Commissioner's order by ordinary mail meets constitutional requirements of procedural due process |
| 20-880 |
Michael H. Holland, as Trustee for the United Mine Workers of America Combined Benefit Fund and United Mine Workers of America 1992 Benefit Plan, et al. v. Westmoreland Coal Company, et al. |
Fifth Circuit |
2021-01-04 |
Denied |
Response RequestedRelisted (2) |
anti-injunction-act bankruptcy-code circuit-split coal-act south-carolina-v-regan statutory-interpretation tax tax-assessment |
Is the South Carolina v. Regan exception to the Anti-Injunction Act available to debtors who want to avoid paying a tax for reasons unrelated to the t… |
| 20-620 |
Anthony Dwayne Williams, et al. v. Commissioner of Internal Revenue |
Fifth Circuit |
2020-11-09 |
Denied |
Response Waived |
constitutional-protections constitutional-rights due-process excise-tax federal-income-tax internal-revenue-code nontaxpayer nontaxpayer-status statutory-notice tax-assessment tax-liability taxpayer |
Should the United States Federal Income Tax be viewed differently when determining the assessment for the liability or penalty for a taxpayer versus a… |
| 20-316 |
Maria Pappas, Cook County Treasurer, et al. v. A.F. Moore & Associates, Inc., et al. |
Seventh Circuit |
2020-09-10 |
Denied |
Amici (1) |
civil-rights comity-doctrine due-process equal-protection real-estate real-estate-assessment tax-assessment tax-injunction-act tax-refund |
Whether the Equal Protection Clause mandates that a real estate taxpayer seeking a refund based on an over assessment of real property be able to chal… |
| 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… |
| 19-8534 |
Robert W. Johnson v. Performant Recovery, Inc., et al. |
Ninth Circuit |
2020-05-23 |
Dismissed |
IFP |
civil-procedure constitutional-rights due-process jurisdiction standing tax-assessment |
Whether the Department of the Treasury had jurisdiction to assess taxes against the petitioner for IRS civil matters |
| 19-7576 |
James Anthony Davis v. Angleton Independent School District, et al. |
Texas |
2020-02-05 |
Denied |
Response WaivedRelisted (2)IFP |
civil-procedure due-process government-interference necessary-parties property-rights res-judicata taking-clause takings tax-assessment |
Whether the Petitioner could be liable for the 2012 taxes as he was not the property owner on January 01, 2012 |
| 19-261 |
Steven T. Waltner, et ux. v. Commissioner of Internal Revenue |
Ninth Circuit |
2019-08-28 |
Denied |
Response WaivedRelisted (2) |
appellate-jurisdiction collateral-estoppel due-process informal-notice statute-of-limitations sua-sponte-sanction tax-appeal tax-assessment tax-assessment-statute-of-limitations tax-code tax-court tax-return valid-return |
Whether the court below erred in holding that Petitioners' timely-filed tax return did not start the running of the 3-year statute of limitations on a… |
| 19-5151 |
Jeffrey T. Maehr v. United States |
Federal Circuit |
2019-07-11 |
Denied |
Response WaivedRelisted (2)IFP |
16th-amendment due-process findings-of-fact grand-jury-access income-definition irs-actions standing standing-precedent stare-decisis tax-assessment tax-assessments tax-levies |
Can the IRS/United States government Respondent and lower courts consistently call U.S. Supreme Court standing case precedent (stare decisis) on the d… |
| 19-57 |
Donald Dewees v. United States |
District of Columbia |
2019-07-09 |
Denied |
Response Waived |
administrative-procedure due-process eighth-amendment equal-protection excessive-fines international-tax international-taxation streamlined-filing-compliance-procedures tax-assessment tax-collection tax-compliance tax-convention tax-penalties |
Did the lack of a meaningful review of the assessment and collection of a tax under the Convention violate Dewees' right to due-process? |
| 18-9433 |
Timothy J. Stubbs v. United States |
Tenth Circuit |
2019-05-29 |
Denied |
Response WaivedIFP |
burden-of-proof criminal-activity financial-records financial-transparency fraud fraud-or-deceit kawashima-v-holder sentencing-enhancement sophisticated-means tax-assessment tax-evasion |
Does the Government meet its burden of proof in a tax evasion case (as opposed to failure to file) where the financial records of the accused are trut… |
| 18-1468 |
United Mine Workers of America Combined Benefit Fund, et al. v. Andre M. Toffel, as Chapter 7 Trustee for Walter Energy Inc., et al. |
Eleventh Circuit |
2019-05-24 |
Denied |
Response Waived |
1992-plan-premiums anti-injunction-act bankruptcy-code bankruptcy-code-section-1114 circuit-split coal-act south-carolina-v-regan statutory-interpretation tax-assessment tax-validity |
Whether the South Carolina v. Regan exception to the Anti-Injunction Act applies only in this Court and, if not, whether it applies only to litigants … |
| 18-9099 |
Jean-Gespere Pierre v. Alliance Security Services, et al. |
Second Circuit |
2019-05-03 |
Denied |
IFP |
civil-procedure-standing-due-process-takings-pate ' 'civil-procedure" ' 'civil-rights" ' 'due-process" ' 'patent' ' 'standing" ' 'takings" administrative-law civil-procedure due-process jurisdictional-challenge property-rights tax-assessment |
Whether the lower court erred in dismissing the petitioner's claims related to due-process, civil-rights, standing, civil-procedure, takings, patent |
| 18-792 |
Ronald Leroy Satterlee v. Alicia Miller-Degase, Assessor of Douglas County, Missouri, et al. |
Missouri |
2018-12-20 |
Denied |
Response Waived |
civil-rights constitutional-rights contract-rights due-process government-authority jurisdiction jurisdiction-challenge presumption-of-innocence property-rights property-tax right-of-contract tax-assessment taxation |
Whether the appellant has the right to life, liberty, property and pursuit of happiness, the right to presumption of innocence, the right of contract,… |
| 18-297 |
Eric White, et al. v. Barbara D. Underwood, Attorney General of New York, et al. |
New York |
2018-09-07 |
Denied |
Amici (1)Response Waived |
canons-of-construction federal-indian-law indian-law indian-rights indian-treaty-rights native-american-rights new-york-indians seneca-nation sovereign-immunity state-taxation statutory-interpretation supreme-court-precedent tax-assessment treaty-interpretation tribal-sovereignty |
Does New York's assessment and collection of taxes within the Seneca Nation of Indians violate the treaty rights of the Seneca Nation? |
| 18-205 |
Northern California Water Association, et al. v. California State Water Resources Control Board, et al. |
California |
2018-08-16 |
Denied |
Response Waived |
central-valley-project federal-property intergovernmental-immunity preemption property-rights sovereign-immunity state-taxation state-water-board supremacy-clause tax-assessment taxation water-contractors water-contracts water-rights |
Is a California statute imposing a direct tax on the United States' property interest in water constitutional if it is applied in a manner that passes… |