| 22-1179 |
Sabena Puri v. United States |
Ninth Circuit |
2023-06-06 |
Denied |
Response Waived |
abuse-of-process foreign-government-inquiry good-faith irs-summons judicial-process judicial-review powell-framework tax-treaty treaty-request united-states-v-powell united-states-v-stuart |
Is a foreign government's abusive or bad faith purpose ever relevant to the enforcement of an IRS summons issued pursuant to a treaty request? |
| 20-1300 |
Emilio Torres Luque, et al. v. Commissioner of Internal Revenue |
Ninth Circuit |
2021-03-19 |
Denied |
Response Waived |
cross-border-residency double-taxation international-tax-law ninth-circuit reciprocity residency revenue-procedure supremacy-clause tax-treaty treaty-interpretation |
Is the US-Mexico tax treaty being applied correctly to dual residents? |
| 20-6639 |
Todd Anthony Aurit v. Colorado |
Colorado |
2020-12-16 |
Denied |
IFP |
detention-authority foreign-estate foreign-person foreign-trust internal-revenue-code non-us-person tax-treaties tax-treaty taxpayer-relief-act |
Whether the State of Colorado has lawful authority to detain the petitioner and his foreign estate and trust |