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Henry J. Langer, et ux. v. Commissioner of Internal Revenue

Paid petition · United States Court of Appeals for the Eighth Circuit, No. 17-3682 · judgment September 18, 2018

Certiorari denied · April 15, 2019
Pre-decision estimate: 0% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

For Re view Henry J. Langer and Patricia K. Langer (taxpayers) appealed the decision of the United States Tax Court which states "th at the judgment of the tax court in this cause is aff irmed in accordance with the opinion of thi s Court". Whether Respondent has proved by clear and convincing evidence that Henry J. Langer is liable for the fraud penalty for th e years 2011, 2012, and 2013? Whether Respondent has proved by clear and convincing evidence that Pa tricia K. Langer is liable for the fraud pena lty for the years 2011, 2012, and 2013?

Counsel of record

For petitioner
Henry J. Langer

For respondent
Noel John Francisco
Jones Day

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Apr 15 2019
    Petition DENIED.
  2. Mar 27 2019
    DISTRIBUTED for Conference of 4/12/2019.
  3. Mar 22 2019
    Waiver of right of respondent CIR to respond filed.
  4. Feb 25 2019
    Petition for a writ of certiorari filed. (Response due April 1, 2019)