Supreme Court of the United States · Official docket →

Interior Glass Systems, Inc. v. United States

Paid petition · United States Court of Appeals for the Ninth Circuit, No. 17-15713 · judgment June 26, 2019

Certiorari denied · December 9, 2019

Pre-decision estimate: 2% cert probability

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

Questions presented

Is the collection of tax penalties an exception to the requirements of due process, or does a citizen have a right to a hearing before the IRS seizes thousands, or even millions, of dollars in tax penalties?
If the citizen has a right to a hearing, does a meeting with an IRS Appeals Officer satisfy the requirement of a “meaningful” pre-collection hearing?
Does the IRS’s broad interpretation of “substantially similar” render the penalty statute so vague and unpredictable that no person of “common intelligence” could anticipate what types of plans would need to be reported?

For petitioner
John Patrick McDonnell
Law Offices of John P. McDonnell

For respondent
Noel John Francisco
Jones Day

Conference history
Distributed for 1 conference

Dec 09 2019
Petition DENIED.
Nov 20 2019
DISTRIBUTED for Conference of 12/6/2019.
Nov 12 2019
Waiver of right of respondent United States to respond filed.
Oct 30 2019
Petition for a writ of certiorari filed. (Response due December 2, 2019)