Supreme Court of the United States · Official docket →
Vito Manente v. Commissioner of Internal Revenue
Paid petition · United States Court of Appeals for the Third Circuit, No. 24-2548 · judgment April 9, 2025
Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.
Questions presented
The U.S. Const., art. 1, sec. 2, cl. 3 states that “Representatives and direct Taxes shall be apportioned among the several States ...” The U.S. Const., art. 1, sec. 9, cl. 4 states that “No capitation, or other direct, tax shall be laid, unless in proportion to the census or enumeration herein before directed to be taken.” The Questions Presented are:
-
Has the Sixteenth Amendment negated U.S. Const., art. 1, sec. 2, cl. 3 and U.S. Const, art. 1, sec. 9, cl. 4 by allowing taxation on a sovereign person’s labor and to clarify not wages as divined in the Internal Revenue Code (26 U.S. Code § 3401(c))?
-
Do the Sixteenth Amendment and 26 U.S.C. § 7701(a)(9)-(10) apply to the Constitutional fifty States of the Union or to the Statutory District of Columbia and the territories thereof (e.g. Guam)?
Counsel of record
For petitioner
Vito Manente
For respondent
D. John Sauer
Solicitor General
Case
Conference history
Distributed for 1 conference
Proceedings
- Oct 06 2025Petition DENIED.
- Aug 20 2025DISTRIBUTED for Conference of 9/29/2025.
- Aug 18 2025Waiver of right of respondent Respondent to respond filed.
- Jun 09 2025Petition for a writ of certiorari filed. (Response due September 15, 2025)