tax-penalty

Case	Title	Lower Court	Docketed	Status	Flags	Tags	Question Presented
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…
21-631	Emily S. Wilson, as Executrix of the Estate of Joseph A. Wilson, et al. v. United States	Second Circuit	2021-10-29	Denied	Response Waived	administrative-law chevron-deference foreign-trust irs-policy irs-reporting statutory-interpretation tax-law tax-penalty	Whether the Court of Appeals erred in not resolving the ambiguity in the statutory provisions of 28 U.S.C. §§ 6048 and 6677 in favor of Petitioners
20-1697	Alice Kimble v. United States	Federal Circuit	2021-06-09	Denied	Response Waived	8th-amendment eighth-amendment excessive-fine fbar foreign-bank-account-report statutory-interpretation tax-evasion tax-penalty willful-violation willfulness	Did the Court err in holding that Alice acted willfully, despite the lack of proof either that she had knowledge of the requirement to file an FBAR or…