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Frank W. Bibeau v. Commissioner of Internal Revenue

Paid petition · United States Court of Appeals for the Eighth Circuit, No. 23-2923 · judgment July 19, 2024


Certiorari denied · March 3, 2025
Pre-decision estimate: 0% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

The Commissioner of Internal Revenue, a federal agency, applied federal income tax to the on-reservation income of an Indian despite a constitutional provision that Indians Not [be] Taxed and in the absence of an Act of Congress clearly authorizing the tax. The question presented is: Did the Court of Appeals err in upholding federal income tax on an individual Indian’s self-employment income earned on his Tribe’s reservation without Treaty, constitutional, or congressional expressly stated authorization for that taxation?

Counsel of record

For petitioner
Frank Warren Bibeau
BIBEAU LAW OFFICE

For respondent
Sarah M. Harris
Acting Solicitor General

Case

Conference history
Distributed for 1 conference

Amicus briefs
1 cert-stage

Linked docket
24A567

Proceedings

  1. Mar 03 2025
    Petition DENIED.
  2. Feb 13 2025
    Brief amicus curiae of Sauk-Suiattle Indian Tribe filed. (Distributed)
  3. Feb 12 2025
    DISTRIBUTED for Conference of 2/28/2025.
  4. Feb 10 2025
    Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
  5. Jan 24 2025
    Petition for a writ of certiorari filed. (Response due February 27, 2025)
  6. Dec 12 2024
    Application (24A567) granted by Justice Kavanaugh extending the time to file until January 24, 2025.
  7. Dec 04 2024
    Application (24A567) to extend the time to file a petition for a writ of certiorari from December 25, 2024 to January 24, 2025, submitted to Justice Kavanaugh.