Gary S. Christensen v. United States

Question 1 Does this Court’s holding in Return Mail, Inc. v. United States Postal Service, 139 S. Ct. 1853 (2019) overturn every case holding the Internal Revenue Service is a “victim” entitled to restitution, and clarify that federal courts have no subject matter jurisdiction to order restitution in criminal tax cases? Question 2 Does a restitution order based on estimates rather than finally determined taxes render 26 U.S.C. § 6201(a)(4) unconstitutional, in that the statute bars criminal defendants from contesting IRS restitution assessments, depriving them of property without the due process afforded all other taxpayers?