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Jon D. Adams v. Commissioner of Internal Revenue

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 19-60790 · judgment June 30, 2020


Certiorari denied · November 23, 2020
Pre-decision estimate: 1% cert probability

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

Question presented

The Appellant (hereinafter referred to as “the Taxpayer”) is seeking abatement of interest assessed by the Appellee (hereinafter referred to as “the Commissioner”) for the 1999 tax year, to which the Commissioner has denied. The question presented for review by the Supreme Court of the United States of America is whether the Fifth Circuit Court of Appeals erred in holding that the Taxpayer was not entitled to interest abatement under 26 U.S.C.A. § 6404(e) when it relied on Lee v. Commissioner, which has been distinguished by more recent case law. –i–

Counsel of record

For petitioner
James Gary McGee
McGee Tax Law, PLLC

For respondent
Jeffrey B. Wall
Sullivan & Cromwell LLP

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Nov 23 2020
    Petition DENIED.
  2. Nov 04 2020
    DISTRIBUTED for Conference of 11/20/2020.
  3. Nov 02 2020
    Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
  4. Oct 26 2020
    Petition for a writ of certiorari filed. (Response due November 30, 2020)