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Rocky Branch Timberlands LLC v. United States, et al.

Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 22-12646 · judgment September 6, 2023


Certiorari denied · February 20, 2024
Pre-decision estimate: 6% cert probability (95% interval 4%–10%)

Before the decision, about 1.5× the 4.1% base rate. The model weighted this up for an Eleventh Circuit decision below, a petition filed soon after the judgment below, and a business petitioner.

Question presented

Whether the Anti-Injunction Act’s bar on lawsuits for the purpose of restraining the assessment or collection of taxes also bars courts from enforcing laws which require the IRS to provide taxpayers with their due process rights.

Counsel of record

For petitioner
Samuel Fenn Little Jr.
S. Fenn Little, Jr., PC

For respondent
Elizabeth B. Prelogar
Solicitor General

Case

Conference history
Distributed for 1 conference

Order
Order list, February 20, 2024 · Certiorari denied

Proceedings

  1. Feb 20 2024
    Petition DENIED.
  2. Jan 24 2024
    DISTRIBUTED for Conference of 2/16/2024.
  3. Jan 05 2024
    Waiver of right of respondent Federal Respondents to respond filed.
  4. Dec 05 2023
    Petition for a writ of certiorari filed. (Response due January 8, 2024)