Supreme Court of the United States · Official docket →

Richard E. Boggs v. United States

Paid petition · United States Court of Appeals for the Fourth Circuit, No. 19-2084 · judgment March 2, 2020

Certiorari denied · November 9, 2020

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

Did the Internal Revenue Service (IRS) deprive the petitioner of his Constitutional Fifth Amendment right to due process when it failed to offer a basis for its “determination1” that the petitioner was not entitled to claim “Exempt” on his W-4 Withholding Certificate, signed under penalty of perjury, prior to the taking of petitioner s property? Did the IRS and the UNITED STATES deprive the 2) petitioner of the operation of subject provisions 2 relied upon in order to make an unspecified “determination as to the petitioner’s tax liability? Comm’r of IRS, 814 F.2d 1363 (CA9 1987); Benzvi v. Comm r of mS, 787 F.2d 1541 (CA11 )> Maxfield v. U.S. Postal Service, 752 F.2d 433 (1984);WetmerskirchvCommr 360 (CA9 1979); Carson v. U.S., 560 F.2d 693 (1977); U-S-^ams, 428 U.S 433, 442 (1975) A^mn v. “Americans United" Inc., 416 U.S. 752, 758-770 ^ ^ Terminal Wine, 1 B.T.A. 697, 701-02 (1925); Couzens, 11 B.T.A. 1140, 1159, 1179. mean 26 USC §§ raiss:^ t». 7621 7651(4)(A) 7655; 42 USC § 411(b)(2); 26 CFR l.l-l(a) - (c), 1.83-3(e), (f),.(g). 1 1001-l(a) 1.1011-1(a), 1.1012-lCa), 1.1401-l(a), 1.1402(a)-2(a), 1.1402(b)-1(d), 31.0-2(a)(l), 31 3121(e)-l(b), 301.6201-l(a), and 602.101. (See Appendix A19)

For petitioner
Richard E. Boggs

For respondent
Jeffrey B. Wall
Sullivan & Cromwell LLP

Conference history
Distributed for 1 conference

Nov 09 2020
Petition DENIED.
Oct 21 2020
DISTRIBUTED for Conference of 11/6/2020.
Oct 15 2020
Waiver of right of respondent United States to respond filed.
Sep 08 2020
Petition for a writ of certiorari filed. (Response due November 9, 2020)