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Tax (Civil)

Every decision we've filed under Tax (Civil).

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Mar 25 2026
11th Cir. 25-10744 Per Curiam

JACKSON CROSSROADS LLC Greencone Investments, LLC Tax Matters Partner v. COMMISSIONER OF INTERNAL REVENUE

The Eleventh Circuit affirmed the Tax Court's decision sustaining 40% gross-valuation-misstatement penalties against LLCs claiming excessive conservation-easement deductions. The court found no error in the lower court's reliance on IRS expert testimony to determine significantly lower fair market values for the easements.

Civil Tax (Civil)
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Mar 20 2026
3rd Cir. 26-1019 Panel Decision

In re SHARISSE JUANITA FILUS, as Trustee and/or Beneficiary of the SJF Living Revocable Trust

The Third Circuit denied in part and dismissed in part a pro se petition for a writ of mandamus filed by Sharisse Filus seeking to intervene in her underlying civil action against Fidelity Investments. The court determined that the District Court's procedural rulings, including the denial of Filus's motions to strike the defendant's answer and impose sanctions, were not appropriate subjects for mandamus relief.

Civil Motion to Dismiss Tax (Civil)
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Mar 10 2026
Fed. Cir. 25-1955 Panel Decision

GEOFFREY A. WILLIAMS v. UNITED STATES 2025-1955

The Federal Circuit affirmed the dismissal of a taxpayer's refund suit because he failed to file a proper refund claim using the required Form 1040 before going to court. The court also held that it lacks jurisdiction over the taxpayer's allegations of fraud and criminal conduct by the IRS.

Civil Tax (Civil)
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Mar 10 2026
United States Court… 24-5172 Panel Decision

MONTE A. ROSE, JR v. ROBERT F. KENNEDY, JR., SECRETARY, UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES

The D.C. Circuit dismissed Indiana's appeal of a district court order remanding a Medicaid dispute to HHS because the remand order was not a final decision under 28 U.S.C. § 1291. The court held that the order left the core dispute unresolved for further agency proceedings, and no exceptions to the finality rule applied.

Appellate Jurisdiction Civil Tax (Civil)
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Mar 2 2026
3rd Cir. 3:22-cv-04476 Panel Decision

UNITED STATES OF AMERICA v. ALBERT BOUFARAH

The Third Circuit affirmed summary judgment for the Government in a federal tax collection suit, ruling that IRS transcripts containing minor clerical errors remain admissible to prove tax liability. The court held that the evidence was sufficient to show the taxpayer's installment agreements had terminated months before the lawsuit was filed.

Civil Summary Judgment Tax (Civil)
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Feb 27 2026
1st Cir. 25-1249 Panel Decision

IN RE: STEVEN T. SAVAGE; VIRGINIA A. SAVAGE Debtors COASTAL CAPITAL, LLC v. STEVEN T. SAVAGE; VIRGINIA A. SAVAGE

The First Circuit affirmed the denial of a Chapter 7 bankruptcy discharge for the Savages because they failed to satisfactorily explain the disposition of assets received from their company prior to filing. The court rejected the argument that only substantial asset losses or those sufficient to pay all liabilities require explanation under the Bankruptcy Code.

Civil Tax (Civil)
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Feb 17 2026
United States Court… 24-5276 Panel Decision

PATRICK LENZ, DR., EXECUTOR OF THE ESTATE OF HARRY S. STONEHILL v. INTERNAL REVENUE SERVICE

The D.C. Circuit affirmed the denial of a motion to vacate a 2008 FOIA judgment, ruling that the movant failed to prove fraud on the court by clear and convincing evidence. The court also upheld the lower court's decision to treat the motion as untimely under Federal Rule of Civil Procedure 60(b)(3).

Civil FOIA Summary Judgment Tax (Civil)
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Dec 11 2025
1st Cir. Nos. 24-1532, 24-1614, 24-1734 Panel Decision

Orkin v. Albert

The First Circuit vacated and remanded a district court judgment in a family business dispute, finding that the lower court failed to properly apply partnership and implied contract principles to the siblings' decade-long conduct. The appellate court held that the siblings' long-standing practice of treating personal expenses as compensation created an implied agreement, requiring a new determination of Orkin's rightful share of Boost Web funds.

Civil Tax (Civil)
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