In Re Roger Rowe

Whether Petitioner is entitled to relief from a judgment and orders from the Second Circuit court, which conflicts with a decision of this Court or has so far departed from the accepted and usual course of judicial proceedings, or sanctioned such a departure by a lower court?

Whether the District Court violated Petitioner’s substantive and procedural due process when it presided over an action to reduce a lien to judg­ ment beyond the 6-year statute of limits and its corresponding 10-year collection extension period?

Did the Government deprive Petitioner of his due process when it failed to timely notify him (within 60-days of the assessment) of its intent to assess corporate tax liability against him or give him the opportunity to timely challenge the liability (pro­ vide 90-day demand notice)?

Whether the record met the substantial evidence threshold that a reasonable mind could accept as adequate to support its conclusion, relative to the accuracy of dueling assessments and the agencies confirmation that the lien statute had expired?

Whether the Government is subject to damages under Biven’s for clearly violating established statutory or constitutional rights when it failed to disclose exculpatory evidence and release an im­ proper lien.