Supreme Court of the United States · Official docket →
Jehan Agrama v. United States
Paid petition · United States Court of Appeals for the Ninth Circuit, No. 22-55447 · judgment July 12, 2023
Before the decision, modestly above the 4.1% base rate. The model weighted this up for a circuit split argued in the petition and a Ninth Circuit decision below.
Questions presented
-
Whether the district court erred under United States v. Powell, 379 U.S. 48 (1964), and United States v. Clarke, 573 U.S. 248 (2014), in enforcing the IRS summons even though the IRS admittedly already possesses summoned documents.
-
Whether the district court erred under Powell and Clarke in enforcing the IRS summons even though the IRS investigation reflects information obtained through unconstitutional searches.
-
Whether the district court erred under Powell and the principle of international comity in enforcing the IRS summons even though the summons seeks to circumvent the disclosure regime imposed by multiple foreign treaties. (i)
Counsel of record
For petitioner
David M. Lehn
Boies Schiller Flexner LLP
For respondent
Elizabeth B. Prelogar
Solicitor General
Case
Subject area
Federal Taxation (estimated from the questions presented, in the Supreme Court Database’s categories)
Conference history
Distributed for 1 conference
Linked docket
23A501
Order
Order list, March 18, 2024 · Certiorari denied
Proceedings
- Mar 18 2024Petition DENIED.
- Feb 28 2024DISTRIBUTED for Conference of 3/15/2024.
- Feb 22 2024Waiver of right of respondent United States to respond filed.
- Jan 19 2024Petition for a writ of certiorari filed. (Response due February 22, 2024)
- Dec 04 2023Application (23A501) granted by Justice Kagan extending the time to file until January 19, 2024.
- Nov 29 2023Application (23A501) to extend the time to file a petition for a writ of certiorari from December 20, 2023 to January 19, 2024, submitted to Justice Kagan.