| 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 |
| 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 |
| 21-7531 |
Michael G. Peters v. City of Houston, Texas, et al. |
Fifth Circuit |
2022-04-04 |
Dismissed |
IFP |
certiorari-petition civil-procedure civil-rights court-review due-process federal-tax-code free-speech legal-procedure standing statutory-interpretation takings tax-liability |
Whether the court erred in dismissing petitioner's claims |
| 21-1203 |
In Re Roger Rowe |
|
2022-03-02 |
Denied |
Response WaivedRelisted (2) |
agency-procedure civil-procedure civil-rights constitutional-rights due-process judicial-proceedings judicial-review lien standing statute-of-limitations tax-liability |
Whether Petitioner is entitled to relief from a judgment and orders from the Second Circuit court |
| 21-1067 |
Ra Nu Ra Khuti Amen Bey v. United States |
Federal Circuit |
2022-02-01 |
Denied |
Response Waived |
civil-rights constitutional-rights due-process federal-jurisdiction federal-questions original-issue-discount secured-party-creditor standing takings tax tax-liability |
Whether plaintiffs' erroneously given 'inferior status' and denied the right to redress the UNITED STATES on obligations such as certificates of indeb… |
| 21-338 |
Gary S. Christensen v. United States |
Ninth Circuit |
2021-09-02 |
Denied |
Response Waived |
16th-amendment criminal-tax due-process equal-protection federal-jurisdiction irs-determination precedent-interpretation restitution sixteenth-amendment tax-liability |
Where no determination of federal tax liability has been made by the IRS and the court of appeals has ruled patently contrary to this court's decision… |
| 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… |
| 20-460 |
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? |
| 19-1178 |
Robert K. Zabka, et ux. v. United States, et al. |
Seventh Circuit |
2020-03-27 |
Denied |
Response Waived |
appellate-jurisdiction civil-procedure civil-procedure-final-judgment-receivership-appeal conflict-of-laws conflicting-precedent due-process federal-courts final-judgment jurisdiction net-operating-loss partnership-property receivership standing tax-liability timeliness |
Where the court clerk has entered the final appealable judgment, and the district court judge has initialed it as such, and then the litigant appeals … |
| 19-969 |
John M. Marshall, et al. v. Commissioner of Internal Revenue |
Ninth Circuit |
2020-02-03 |
Denied |
Amici (1)Response Waived |
creditor-rights federal-law property-transfer recharacterization state-law stern-v-commissioner tax-law tax-liability transaction-recharacterization |
Whether state law or federal law governs the recharacterization of a transaction for federal tax liability purposes |
| 19-6338 |
Gerald Nelson v. Commissioner of Internal Revenue |
Second Circuit |
2019-10-22 |
Denied |
Response WaivedRelisted (2)IFP |
arbitration arbitration-award back-pay back-pay-settlement civil-rights due-process gross-income gross-income-taxation section-1983 tax tax-law tax-liability unemployment unemployment-benefits |
Whether gross income includes back pay settlements that deduct taxpayer's Unemployment Benefits in an Arbitration Award, and who is the taxpayer - the… |
| 19-435 |
SIH Partners LLLP, Explorer Corporation v. Commissioner of Internal Revenue |
Third Circuit |
2019-10-02 |
Denied |
|
administrative-law agency-interpretation chevron-deference circuit-split irs-regulation revenue-ruling statutory-interpretation tax-liability tax-regulation |
Whether the Third Circuit erred in deferring to the IRS regulation under Chevron |
| 18-1474 |
Sunoco, Inc. v. United States |
Federal Circuit |
2019-05-24 |
Denied |
Amici (1) |
congressional-intent excise-tax federal-circuit renewable-fuels statutory-interpretation tax-credits tax-incentives tax-liability tax-system |
Whether the Federal Circuit properly held that tax credits operate as a reduction of tax liability rather than as a payment of taxes owed |
| 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 |
| 18-1133 |
Henry J. Langer, et ux. v. Commissioner of Internal Revenue |
Eighth Circuit |
2019-03-01 |
Denied |
Response Waived |
8th-circuit burden-of-proof civil-procedure clear-and-convincing-evidence penalty-assessment tax-court tax-court-review tax-evasion tax-fraud tax-liability tax-penalties |
Whether the IRS has proved by clear and convincing evidence that Henry J. Langer and Patricia K. Langer are liable for fraud penalties for tax years 2… |
| 18-1069 |
Diebold Foundation, Inc., Transferee v. Commissioner of Internal Revenue |
Second Circuit |
2019-02-15 |
Denied |
|
circuit-split commissioner-notice jurisdictional-issue second-circuit statutory-interpretation tax-appeals tax-court-jurisdiction tax-liability tax-notice tax-procedure tax-year taxable-year waiver |
Tax-court-jurisdiction,tax-liability,tax-year,tax-notice,tax-appeals,tax-procedure |