Rowland Marcus Andrade, et al. v. Internal Revenue Service

Should the district court have held an evidentiary hearing to address Petitioners’ allegations that pieces of paper purporting to be summonses lacked the essential attributes justifying characterization as summonses?

Did the Notice of Agreed Order filed in the district court on May 23, 2024, preserve the petitioners' right of appeal when it stated that the Movants agree to the order in form and reserve the right to ask the Court to reconsider its rulings and/or appeal the substance of the rulings?

Did the district court, the petitioners, and the respondent consider the Decision of the district court to be final within the meaning of 12 U.S.C. §3410(d) when that Court issued an unopposed stay to its ruling until the Fifth Circuit decides Petitioners’ appeal of that ruling?

Are the forty-one (41) States’ Constit-ution Open Court Provisions (App.22-36) “laws of the several states [that] shall be regarded as rules of decision” pursuant to 28 U.S.C. §1652 tantamount to an amendment of the United States Constitution, given that they typically provide, as is the case under Tex. Const. Art. I, § 13 (App.33-34), that “[a]ll courts shall be open, and every person for an injury done him, in his lands, goods, person or reputation, shall have remedy by due course of law” and given further that it requires only 38 States to ratify an amendment to the Constitution, or if not tantamount to an amendment, laws that should be given considerable weight by this Court in this matter?