Supreme Court of the United States · Official docket →
William A. Goddard, et al. v. United States
Paid petition · United States Court of Appeals for the Ninth Circuit, No. 24-5449 · judgment June 11, 2025
Before the decision, roughly the 4.1% base rate. The model weighted this up for a Ninth Circuit decision below, counsel who has filed here before, and a petition filed soon after the judgment below.
Questions presented
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Whether a law firm can be denied the opportunity to challenge an IRS summons for law firm trust account records based solely on an IRS declaration which states only in general terms that the summons would aid IRS in the collection of taxes owed by a law firm employee.
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Whether an allegation of bad faith actions by an IRS employee that were approved by an IRS manager is sufficient to show bad faith by the agency thereby requiring an evidentiary hearing.
Counsel of record
For petitioner
Bradley A. Patterson
LGI LLP
For respondent
D. John Sauer
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, November 10, 2025 · Certiorari denied
Proceedings
- Nov 10 2025Petition DENIED.
- Oct 08 2025DISTRIBUTED for Conference of 11/7/2025.
- Oct 06 2025Waiver of right of respondent United States to respond filed.
- Sep 09 2025Petition for a writ of certiorari filed. (Response due October 16, 2025)