Posted by: Robert Horwitz | October 1, 2025

Dueling Districts: Does IRS Assessment of a Penalty Without Jury Trial Violate the Seventh Amendment? by Robert S. Horwitz

Two district court opinions issued days apart, United States v. Sagoo, WL 2689912 (N.D. Tex. September 19, 2025), and HDH Group, Inc. v. United States, 2025 WL 2711877 (W.D. Penn. September 23, 2025), reached opposite results to the question of whether the IRS assessment of penalties without a prior jury trial violates the Seventh Amendment. The basis for the decisions conflict, which is why they are dueling districts.

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For more information, please contact Robert S. Horwitz at horwitz@taxlitigator.com

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