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Naren Chaganti v. Commissioner of Internal Revenue

Paid petition · United States Court of Appeals for the Eighth Circuit, No. 17-3804 · judgment December 14, 2018


Certiorari denied · June 17, 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.

Questions presented

  1. Whether stipulations filed under Tax Court Rule 91(a) & (e) are binding on the parties and the Tax Court.

  2. Whether statements in a court order in one case may be used for their truth in a different case over a hearsay objection.

  3. Whether litigation sanctions ordered by a district court and paid to an opposing party are “fines” or “penalties” “paid to a government” under Internal Revenue Code § 162(f) (2006), in light of the change to the code section enacted in the Tax Cuts & Jobs Act of 2017.

Counsel of record

For petitioner
Naren Chaganti
Law Offices of Naren Chaganti

For respondent
Noel John Francisco
Jones Day

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Jun 17 2019
    Petition DENIED.
  2. May 28 2019
    DISTRIBUTED for Conference of 6/13/2019.
  3. May 22 2019
    Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
  4. May 10 2019
    Petition for a writ of certiorari filed. (Response due June 13, 2019)