Craig R. Walcott v. United States

I. Whether this Court should grant certiorari, vacate, and remand (GVR) for reconsideration in light of Moore v. United States, 602 U.S. 572 (2024), where the Tenth Circuit affirmed a §7201 conviction premised entirely on United States v. Collins, 920 F.2d 619 (10th Cir. 1990), without addressing whether Moore abrogated Collins on the constitutional point upon which the prosecution was expressly premised, the sentencing record, the restitution methodology, or the ineffective assistance claim — and where the full court declined to be polled on these questions. II. Whether Moore v. United States, 602 U.S. 572 (2024) — holding income taxes are indirect taxes under Article I, §8 — abrogated United States v. Collins, 920 F.2d 619 (10th Cir. 1990) — holding the Sixteenth Amendment authorizes a direct nonapportioned income tax — thereby invalidating a criminal prosecution expressly premised on the Collins direct-tax theory. III. Whether the United States is a statutory 'person' eligible to receive restitution as a 'victim' under 18 U.S.C. §§3663-3663A — and whether a restitution order and derivative §6201(a)(4) civil assessment premised on Collins must be vacated under United States v. Cooper Corp., 312 U.S. 600 (1941), independent of the Moore/Collins constitutional question.