Supreme Court of the United States · Official docket →
Rockwater, Inc., dba Peerless Manufacturing Company v. United States
Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 23-11893 · judgment November 15, 2024
Before the decision, about 2.3× the 4.1% base rate. The model weighted this up for an Eleventh Circuit decision below, a dissent in the court below, and a business petitioner.
Questions presented
This statutory interpretation case raises the primary question as to the plain (best) meaning of 26 U.S.C. § 7701(a)(48)(A)(i) and, in the context of the federal excise tax scheme under 26 U.S.C. § 4051(a), raises these four interrelated issues regarding the test for applying that statutory exception:
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What role does the ability of a vehicle to transport a load over the highway play in the statutory inquiry under 26 U.S.C. § 7701(a)(48)(A)(i)?
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Does the two-prong test under 26 U.S.C. § 7701(a)(48)(A)(i) require comparison of the vehicle in question to a traditional highway vehicle to identify the special design features and impairments or limitations?
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Whether the phrase “specially designed for the primary function of transporting a particular type of load other than over the public highway…” as used in 26 U.S.C. § 7701(a)(48)(A)(i) requires consideration of the design elements of the entire vehicle or just particular components of the vehicle?
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Does the phrase “substantially limited or impaired” as used in 26 U.S.C. § 7701(a)(48)(A)(i) require consideration of all forms of impairment or limitation?
Counsel of record
For petitioner
David Decoursey Aughtry
Chamberlain, Hrdlicka, et al.
For respondent
Sarah M. Harris
Acting 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
Order
Order list, March 24, 2025 · Certiorari denied
Proceedings
- Mar 24 2025Petition DENIED.
- Feb 26 2025DISTRIBUTED for Conference of 3/21/2025.
- Feb 21 2025Waiver of right of respondent United States to respond filed.
- Feb 13 2025Petition for a writ of certiorari filed. (Response due March 20, 2025)