Adolfo Sandor Montero v. Commissioner of Internal Revenue

1 QUESTIONS FOR REVIEW

1. Under Supreme Court Rule 10(a), whether this court should exercise its “supervisory power” to resolve the conflict among the circuit courts of appeal and other lower courts regarding the proper interpretation and application of the Brushaber1 doctrine, particularly in light of the Court’s recent reaffirmation of that doctrine in Moore2.

2. Under Rule 10(a), whether this court should establish a definitive precedent to halt the continued misrepresentation of the Brushaber and Stanton3 doctrine by multiple circuit courts of appeals and other lower courts.

3. Under Rule 10(a), whether this Court should intervene, through its supervisory power, to prevent future abuses of discretion by the circuit courts of appeals and other lower courts in mischaracterizing a litigant’s reliance on the correct interpretation of the Moore precedent, reaffirming the Brushaber doctrine, as being “frivolous 1 Frank Brushaber v. Union Pacific Railroad Company, 240 U.S. 1, 36 S.Ct. 236. 60 L.Ed. 493 ri916'l 2 Moore v. United States. 22-800 (Jun 20, 2024) 3 John Stanton v. Baltic Mining Company, 240 U.S. 103. 36 S.Ct. 278. 60 L.Ed. 546 (19161