Defendant Jodi Hoskins was convicted of tax evasion after she and her husband failed to pay taxes for income they earned through their Salt Lake City escort service. The government contended the Hoskins' failed to account for more than one million dollars in income generated in cash payments and credit card receipts. At sentencing, the government's tax loss was relevant to potential jail time and restitution under the United States Sentencing Guidelines. To minimize the tax loss for sentencing purposes, the Hoskins' offered hypothetical tax returns to account for the unreported income and attempted to take deductions they claimed they would have been entitled to but for the tax evasion. The district court rejected the hypothetical tax returns and accepted the government's tax-loss estimate. Defendant appealed her eventual sentence, arguing the sentencing judge abused his discretion in establishing the lost taxes. Furthermore, Defendant challenged the sufficiency of the evidence presented against her and the reasonableness of her sentence. Finding no abuse of discretion, and that the evidence presented at trial sufficient to support her sentence, the Tenth Circuit affirmed Defendant's conviction.

The Fond du Lac Band of Lake Superior Chippewa (Band) sued the the Commissioner of the Minnesota Department of Revenue (Commissioner) to prevent taxation of the out-of-state pension income of Band members. The state taxed a Band member's pension earned in Ohio but received on a reservation. The Band argued that the taxation violated due process and was preempted by federal law. The court held that because citizenship provided a constitutional nexus, Minnesota's taxation complied with due process. The court also held that Minnesota's taxation was not preempted where the case was controlled by the general rule: "Absent express federal law to the contrary, Indians going beyond reservation boundaries have generally been held subject to non-discriminatory state law otherwise applicable to all citizens of the state." Accordingly, the judgment of the district court was affirmed.

Blue Lake Rancheria, an Indian tribe, sought a refund of Federal Unemployment Tax Act (FUTA), 26 U.S.C. 3306(c)(7), taxes paid by Mainstay Business Solutions (Mainstay), an employee leasing company wholly owned by the Tribe. At issue was the scope of section 3306(c)(7)'s exception from "employment" and also at issue was whether Mainstay was the common law employer of its leased employees. The court held that the services performed "in the employ of an Indian tribe" were excepted from FUTA's definition of "employment" by section 3306(c)(7) only where a tribe or its instrumentality was a common law employer of the worker performing the services. The court held that because Mainstay was a common law employer of its leased employees during the years in question, it was not required to pay FUTA taxes with respect to those employees. Therefore, the court reversed and remanded with instructions to enter judgment for the Tribe.

In 2008, Olmsted County changed the property tax classification of farmland owned by Frederick Farms from agricultural-homestead to agricultural-nonhomestead property. The tax court denied Frederick Farms' petition to change the classification of the property back to agricultural homestead for taxes payable in 2009 and later. Frederick Farms appealed, arguing that it was operating a joint family farm venture with its sole shareholder, James Frederick, and that the County must classify the property as agricultural homestead because it was used by the joint family farm venture. The Supreme Court affirmed the decision of the tax court, concluding (1) that a joint family farm venture must own or lease, and not merely use, the property in order for a participant of the joint family farm venture to claim an agricultural-homestead classification; and (2) because the family farm corporation, not the joint family farm venture, owned the land in question, Frederick Farms was not entitled to claim an agricultural-homestead classification as a participant in a joint family farm venture.

In connection with an assessment of a taxpayer for unpaid taxes, the IRS began searching for the taxpayer's assets and issued a summons to a bank for a related third party's account information. The taxpayer and third party argued that 26 U.S.C 7609 required the IRS to notify them, which would have enabled them to seek a court order quashing the summons. Applying Ip v. United States, the court held that under the circumstances of the case, no notice was necessary. Therefore, the court affirmed the judgment of the district court.

Defendant was convicted of four counts of tax evasion and sentenced to 18 months imprisonment. Defendant appealed his convictions, arguing that the government constructively amended the indictment through the evidence presented at trial; the instructions erroneously defined "taxable income" and "good faith"; and the evidence was insufficient to support his convictions. The government appealed defendant's sentence, contending that the district court erroneously relied on a fact rejected by the jury in imposing a sentence below the applicable Sentencing Guidelines range. The court held that neither a constructive amendment nor a variance occurred; the jury was properly instructed and defendant's arguments to the contrary were rejected; and there was sufficient evidence for the jury to convict defendant. The court also held that the district court did not commit a procedural error and that the sentence was substantively reasonable. Accordingly, the judgment of the district court was affirmed.

A jury found defendant, a licensed attorney, responsible for trust fund recovery penalties imposed by the IRS pursuant to 26 U.S.C. (I.R.C.) 6672 for unpaid employment taxes owed by Iowa Trade Bindery, Inc. (ITB). Defendant appealed the district court's judgment and "all adverse rulings and orders in this case." The court held that the district court did not abuse its discretion in admitting defendant's signed Form 2751 and an IRS officer's testimony about the form, or by instructing the jury with respect to the form and its effect. The court also held that the district court did not err in denying defendant's motion for judgment as a matter of law where the jury's verdict was supported by substantial evidence. The court concluded that defendant's remaining claims were without merit. Accordingly, the court affirmed the judgment of the district court.

This case arose when taxpayer transferred membership units in a family-owned LLC partly as a gift and partly by a sale to two trusts and coupled the transfers with simultaneous gifts of LLC units to two charitable foundations. Subsequent to an IRS audit, which determined that the units had been undervalued, the foundations discovered they would receive additional units. At issue was whether the taxpayer was entitled to a charitable deduction equal to the value of the additional units the foundations would receive. The court held that Treasury Regulation 25.2522(c)-3(b)(1) did not bar a charitable deduction equal to the value of the additional units the foundations would receive. Therefore, the court affirmed the judgment.

Two taxpayers filed a petition for declaratory judgment challenging the constitutional validity of Mo. Rev. Stat. 99.1205, the Distressed Areas Land Assemblage Tax Credit Act. The taxpayers claimed that the tax credits provided by the Act constituted an unconstitutional grant or lending of public money to private persons, associations, or corporations. The trial court declined to enter declaratory judgment, concluding that the taxpayers did not have standing to challenge the statute. On appeal, the taxpayers argued they had standing because the tax credits were direct expenditures of funds generated through taxation and that the tax credits given under the Act were unconstitutional. The Supreme Court affirmed, concluding (1) the taxpayers did not meet their burden to prove they had standing to bring a challenge to the statute as the issuance of tax credits does not constitute a direct expenditure of funds generated through taxation, and (2) in accordance with Arizona Christian School Tuition Organization v. Winn, tax credits are not government expenditures and any effect on taxpayers in general is "merely speculative."

The Township brought a putative class action on behalf of itself and similarly situated New Jersey municipalities, alleging that defendants, companies who operate hotel booking sites online, owe unpaid hotel occupancy taxes. Defendants calculate the tax owed based on the negotiated rate paid by a defendant (wholesale rate), not the higher rate charged consumers (retail rate). Defendants pay the tax to the hotel, which remits it to the state taxing authority.The district court dismissed on grounds of prudential standing, holding that state officials have the right to enforce the statutory tax scheme. The Third Circuit affirmed. The Township is not the proper plaintiff. Authority to adopt a hotel tax is granted municipalities by N.J. Stat. 40:48F-1, but administration and collection are left to state officials.