Neither Sword Nor Purse

Why you should read this. On June 23, 2026, the Supreme Court decided Pung v. Isabella County. A Michigan county had sold a family home at auction for $76,008 to collect $2,241.93 of unpaid property tax. The house was assessed at $194,400 for tax purposes; nearly 18 months later, the buyer resold it for $195,000. The Court held that when a tax sale is fairly conducted, the auction price measures what the owner is owed. Two years earlier, in Connelly v. United States, a unanimous Court upheld an estate-tax valuation of a family business stake about $2.3 million above the value reported, because of life insurance the family had bought to keep the business in the family.

Neither opinion reads like a tax treatise. Both decide who keeps the money. This report explains why a court built with no power over the purse decides so many fights about it, what 2,890 coded decisions say about two centuries of that work, and which holdings, read with their limits, belong in your next buy-sell agreement, trust review, or refund claim. Read it before the agreement goes to signature. An estate audit may test it afterward.

On February 1, 1790, Chief Justice John Jay tried to open the first session of the Supreme Court of the United States, in the Royal Exchange in New York. He could not. Some of the Justices were still on the road, and the Court had to wait a day for a quorum. When it finally sat, it had no cases. It admitted lawyers to its bar, settled a few procedural questions, and adjourned on February 10.

Six years later the Court took up one of its first constitutional questions, and it was about a tax. Daniel Hylton of Virginia stipulated that he kept 125 chariots for his own use (enough to support a $2,000 judgment that could be discharged by paying $16) in a suit, the record says, “brought merely to try the constitutionality of the tax.” The Court upheld Congress’s carriage tax in 1796, seven years before Marbury v. Madison.

Myron Scholes and his co-authors gave the modern version of that story one line: “the taxing authority is an uninvited party to all contracts.” Every agreement a family, founder, or fund signs has that silent party at the table. When the parties and the uninvited guest disagree about what was agreed, the dispute can end in a court that, by design, levies no taxes, appropriates no money, and commands no army; it depends on the executive to carry out its judgments, though it keeps contempt and writ powers of its own.

That is the thread of this report. The Court’s tax decisions are less about rates than about power: who may tax, how much, and who keeps what is left. A tax case is defined by what it decides, not by what a database calls it, and its value to a client lies in the holding read with its limits.

Executive summary

2,890 is a coded benchmark, not a census. That many of the 29,270 decisions in the Supreme Court Database (9.9%) carry one of nine tax or fiscal issue codes. The set includes fiscal disputes that are not about taxes and misses major tax decisions filed under other doctrines.

The tax docket peaked in the Depression. In 1931, 59 of the 176 decisions recorded in the database (33.5%) carried a selected tax or fiscal code. The 1930s produced 447, or 15.5% of the benchmark. Since 2000 there have been 54.

Connelly is the priority case for business succession. Corporate-owned life insurance raised the estate-tax value of Michael Connelly’s 77.18% stake from the $3 million reported to about $5.3 million; the company’s redemption obligation did not offset the proceeds. The IRS determined an $889,914 deficiency.

Pung fixes the measure, not the fight. For a fairly conducted tax sale, the auction price is the Takings Clause baseline, and all nine Justices rejected the Excessive Fines claim. Whether this sale was fair returns to the Sixth Circuit, if the objections were preserved.

Moore is narrower than its headlines. The Court sustained the §965 transition tax as attribution of a foreign corporation’s realized, undistributed income to its U.S. shareholders, and said its holding “applies when Congress treats the entity as a pass-through.” The entity was a foreign corporation; “pass-through” is the Court’s word for the attribution, not a partnership. It did not decide a wealth tax or a general realization requirement.

Learning Resources split its votes, and refunds are not automatic. Six Justices held that IEEPA does not authorize the tariffs; only three joined the major-questions parts. Importers must claim refunds through CBP’s CAPE process or, for some finally liquidated entries, through the courts.

McReynolds and Stone lead the counts. James McReynolds participated in 885 benchmark decisions; Harlan Fiske Stone wrote 129 opinions of the Court. Those are measures of activity, not influence.

Seven in ten carried no recorded merits dissent. That is 2,047 of 2,890 (70.8%), a figure older dissent conventions inflate; agreement on the result is not agreement on the reasoning. Only 115 (4.0%) were recorded as 5–4.

01 The branch with no purse

Montesquieu’s system works in tax as he hoped it would: each branch checks the others, and sometimes the people check the Court. Five moments make the point.

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Exhibit 1. Who checked whom over the purse. Sources: the opinions cited in Appendix A; U.S. Const. amend. XVI.

“It is one thing for a state legislature to choose such a regime. It is quite another for this Court to impose such a regime as a matter of constitutional law.” Pung v. Isabella County, slip op. 9 n.3 (2026)

Keep that sentence in mind as you read the recent cases. Again and again, the Court’s answer to a tax dispute is a statement about who decides. Clients who read the holdings as statements about power, not just about money, read them correctly.

02 What the cases decide for clients

Start with the use, not the history. Exhibit 2 pairs ten situations our clients bring us with the decisions that frame them, the facts that decide how those decisions apply, and a first step. It is a diligence list, not an opinion on any transaction.

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Exhibit 2. Ten client situations and where the Court’s cases begin. Case numbers refer to the selected case guide in Appendix A.

03 Connelly: the insurance the valuation could not ignore

Michael and Thomas Connelly were the only shareholders of Crown C Supply, a building-supply company in St. Louis, and they wanted it to stay in the family. Their agreement gave the surviving brother an option to buy a deceased brother’s shares. If he declined, Crown had to redeem them, at a price based on an outside appraisal of Crown’s fair market value. Crown bought $3.5 million of life insurance on each brother to fund the promise.

Michael died in 2013. Thomas declined to buy. Then the family did something ordinary. Rather than commission the appraisal the agreement called for, Michael’s son and Thomas agreed, “in an amicable and expeditious manner,” that Michael’s shares were worth $3 million. Crown paid that amount out of the insurance proceeds, and the estate reported the shares at $3 million.

On audit, the estate’s own appraiser valued Crown at $3.86 million, leaving out the $3 million of insurance earmarked for the redemption; 77.18% of $3.86 million is about $3 million, which seemed to close the loop. The IRS added the insurance back. A unanimous Court, in Justice Thomas’s opinion, agreed: anyone buying Michael’s shares “would acquire a 77.18% stake in a company worth $6.86 million, along with Crown’s obligation to redeem those shares at fair market value.” That is 77.18% of $6.86 million: $5,294,548, or about $5.3 million. The IRS determined an additional $889,914 of estate tax; the estate paid it, sued for a refund, and lost.

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Exhibit 3. How the insurance proceeds affected the estate-tax valuation. Rounded; no discount modeled. The $889,914 is the deficiency the IRS determined on the return as examined, not a rate applied to these figures. Source: Connelly v. United States, 602 U.S. 257 (2024), slip op. 3–4, 6–7.

A drafting rule A corporation’s obligation to redeem shares at fair market value does not, by itself, offset insurance proceeds the corporation collects. The Court said so and said no more: “We do not hold that a redemption obligation can never decrease a corporation’s value.” An obligation that forces the company to sell operating assets, and so cuts its future earnings, may be different (slip op. 9 n.2).

Two more points before anyone redrafts. A price-setting agreement must separately satisfy §2703 to control estate-tax value. And the cross-purchase alternative the Court described is not free: each owner pays the premiums on the other’s life, one may stop paying, and the structure “would have had its own tax consequences.” Compare policy ownership and funding before choosing. Then follow the price mechanism the agreement sets; the Connellys’ negotiated $3 million was not the number the Court used.

04 Tyler and Pung: the surplus and its measure

In Tyler v. Hennepin County, decided in 2023, the county had sold Geraldine Tyler’s Minnesota condominium for $40,000 to cover about $15,000 of tax, interest, and penalties, and kept the $25,000 difference. A unanimous Court held that she had plausibly alleged a taking. The Chief Justice ended with a line every county treasurer now knows: “The taxpayer must render unto Caesar what is Caesar’s, but no more.”

Pung asked the next question: no more than what? The Pung family owed $2,241.93. Isabella County followed Michigan’s statute (a redemption period, public notice, a public auction, and a foreclosure judgment) and sold the house for $76,008. The County initially kept all of it. The district court held the estate entitled to the surplus, $73,766.07, but not to market value, and the Sixth Circuit agreed. The estate wanted the further gap to the $194,400 assessed value.

Exhibit 4. The Pung property. Source: Pung v. Isabella County, No. 25-95, slip op. 2 & n.1 (June 23, 2026); syllabus.

Justice Alito, writing for the Court, held that the auction price is the baseline for just compensation, “at least when the sale is fairly conducted in light of our country’s history of tax sales.” His own example shows why. Take a $100,000 house, $20,000 of unpaid tax, and a $60,000 auction. Under the historical rule, the county keeps $20,000 and returns $40,000. Under the estate’s rule, the county would owe $80,000, and a sale to collect $20,000 “would net the government a $20,000 loss.”

All nine Justices joined Part III, the Excessive Fines holding. Justice Thomas joined the rest of the opinion except Part II-B, which is Takings reasoning, not the fines holding. Writing separately, he recounted the family’s dispute over the underlying assessment, which the majority did not resolve, and concluded that the Pungs “lost about $118,000 as a result of a supposed debt of $2,242.” Justice Sotomayor, joined by Justices Gorsuch and Jackson, wrote to say the Court had not defined what a fair auction requires. The case returns to the Sixth Circuit, which may decide whether the estate’s new procedural objections were preserved and, if so, hear them. Remedies were not before the Court.

The operating rule for tax sales After Tyler, the owner is entitled to the surplus. After Pung, a fairly conducted auction sets its size. Due process requires notice reasonably calculated to inform the owner and, when mailed notice comes back unclaimed, additional reasonable steps if practicable (Jones v. Flowers). That is the constitutional floor; owners, lenders, and heirs should aim higher by keeping addresses current and watching redemption periods.

What makes an auction fair is open. The Court did not define it, did not decide which objections were preserved, and did not reach the remedy for an unfair sale. Do not count on the $118,392 gap. Count on the surplus procedure, and use it.

05 The 2024–2026 decisions and their limits

Recent opinions repay close reading because their headlines travel faster than their qualifications. Each decision below established something real and declined to decide something next to it. Both columns matter.

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Exhibit 5. Recent decisions: holding and limit. Sources: the opinions linked in Appendix A.

How to read a fractured decision. Count the judgment first, then count each part of the opinion. Moore was 7–2 in the judgment. Only five Justices joined Justice Kavanaugh’s opinion; Justices Barrett and Alito concurred only in the judgment, and Justices Thomas and Gorsuch dissented.

In Learning Resources, six Justices joined Parts I, II-A-1, and II-B of the Chief Justice’s opinion. Only the Chief Justice and Justices Gorsuch and Barrett joined Parts II-A-2 and III, where the major-questions reasoning sits. Justice Thomas dissented, and Justice Kavanaugh dissented, joined by Justices Thomas and Alito. The two consolidated cases also ended differently: Learning Resources was vacated and remanded for dismissal for lack of jurisdiction, and V.O.S. Selections was affirmed.

Then apply the rule. A proposition a majority joined is the Court’s. When no rationale commands five votes, Marks v. United States treats as the holding “that position taken by those Members who concurred in the judgments on the narrowest grounds,” so a concurrence can supply the controlling rule (applying Marks is itself contested). A dissent never supplies the holding. Even a sentence five Justices signed may be dicta. A memo that quotes a three-Justice passage as “the Court” invites a correction from the other side.

If you paid IEEPA tariffs (current as of October 4, 2026) The Supreme Court’s decision did not refund anything by itself. CBP opened its Consolidated Administration and Processing of Entries (CAPE) function in ACE on April 20, 2026. Only the importer of record or its filing broker may submit. Phase 1 took unliquidated entries and entries within 80 days of liquidation. On June 29, 2026, CBP added entries flagged for reconciliation (types 01, 02, and 06), on the same timing rules, but only while no reconciliation entry (type 09) has been filed. Sequence matters: obtain CAPE acceptance of the flagged entries before filing the reconciliation entry, unless the reconciliation deadline is close (CBP’s example is less than 30 days), in which case file the reconciliation on time — filing it first makes the underlying entries ineligible for this phase.

Finally liquidated entries are a different matter. In a September 15, 2026 declaration in Freestyle World, Inc. v. CBP, CBP scheduled a Phase 3 launch for October 6, 2026, covering finally liquidated entries of plaintiffs for whom the Court of International Trade ordered reliquidation. Plaintiffs who supplied a valid importer-of-record number by July 30, 2026 may file at launch; CBP said it would give further instructions to plaintiffs who supplied their numbers later. It is not a general reopening. Importers that have not sued should take advice from trade counsel.

Reconcile affected entries and payments with your customs broker, confirm that your ACH refund details are on file (CBP has reported large sums held back for missing bank data), and preserve every protest and litigation deadline. Confirm eligibility and whether Phase 3 has actually launched on the day you file.

06 What two centuries of counting show

How many Supreme Court tax cases are there? The defensible answer depends on the definition, because the Court keeps no official category for decisions about taxes. We therefore built a reproducible benchmark from the Supreme Court Database and kept it separate from everything we did not validate.

Read the total with its definition. 2,890 decisions carry one of nine selected tax or fiscal issue codes. That is a coded benchmark, not a floor, a ceiling, or a census. Automated screens found 215 more candidates (3,105 in all), not yet adjudicated one by one, and we verified 12 tax decisions that every filter missed, including NFIB, Windsor, Tyler, Catholic Charities, and Learning Resources. Twelve demonstrated omissions show a gap; they do not measure it.

The shape is striking. Tax and fiscal disputes were a far larger share of the Court’s recorded docket in the early twentieth century than today. In 1931, 59 of the 176 decisions recorded in the database (33.5%) carried a selected code; the peak Court term is October 1930, with 58. The 1930s produced 447 benchmark decisions, 15.5% of the whole. Since 2000 there have been 54. A falling share does not by itself mean taxation mattered less: the Court’s jurisdiction, its docket, and the database’s coding all changed over the same years, and a decision count measures neither hours nor difficulty.

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Exhibit 6. Benchmark decisions by decade; shares divide by all 2,890 benchmark decisions. The full year-by-year series, 1791–2026, is in the PDF’s Appendix D. Source: SCDB; our calculations.

Two features deserve a flag, not an explanation. The count roughly quadrupled between the 1860s (53) and the 1870s (209). And the switch to the modern file adds 16 decisions that carry a selected code only as a secondary issue. A causal story about either would need its own research design.

The Justices who lead the counts served when the docket was full of tax. James McReynolds participated in 885 benchmark decisions; Harlan Fiske Stone wrote 129 opinions of the Court, ahead of Holmes (122) and McReynolds (108). Adjusted for workload, Benjamin Cardozo leads: 27.4% of his decisions were benchmark cases. Restrict the window to the modern database and William Brennan (313), William O. Douglas (304), and Hugo Black (280) lead. On the current Court, Justice Thomas leads with 104 participations and 15 opinions of the Court, though the benchmark omits crossover cases; the Chief Justice’s eight benchmark opinions, for example, do not include Learning Resources.

Seven in ten benchmark decisions (2,047, or 70.8%) carried no recorded merits dissent, and 115 (4.0%) were recorded as 5–4. Older Courts dissented far less often in writing, so those figures do not compare cleanly with today’s practice. We do not compute a taxpayer win rate: the database’s winning-party field cannot tell which side was the taxpayer across refund suits, immunity disputes, and prosecutions. A credible win rate would require reading the cases. The full counting tables (participation and authorship leaders, voting metrics, and methodology) are in the PDF’s Appendix B and C.

07 Facts worth remembering

1. The record contained 125 chariots. Hylton’s test case rested on a stipulation that he kept 125 chariots for his own use, enough to support a $2,000 judgment that could be discharged by paying $16. The Court sustained the carriage tax without apportionment in 1796.
2. A tomato is a vegetable, in tariff law. Nix v. Hedden (1893) applied the ordinary meaning of the tariff words. The opinion contrasts vegetables served with dinner against fruits usually served as dessert. Statutory context decides the classification, not botany.
3. One controversy, two Pollock decisions. The 1895 income-tax litigation produced an April decision and a May rehearing, which matters for any count. The Sixteenth Amendment later removed apportionment for taxes on incomes “from whatever source derived.”
4. Two married couples, two results, one year. In 1930 Lucas v. Earl refused to honor a contract splitting a husband’s earnings, while Poe v. Seaborn honored the wife’s vested half under Washington community-property law. Ownership under governing law made the difference.
5. A corporation that lived six days. Averill Corporation was formed on September 18, 1928, and dissolved on September 24. In the Second Circuit, Learned Hand wrote that “anyone may so arrange his affairs that his taxes shall be as low as possible” and still held that the transaction failed the reorganization statute. The Supreme Court affirmed in 1935.
6. Holmes’s famous line was a dissent about insurance. “Taxes are what we pay for civilized society, including the chance to insure,” wrote Holmes, joined by Brandeis, in Compañía General de Tabacos (1927). The majority struck a Philippine tax on marine-insurance premiums paid to an unlicensed Paris insurer and sustained it on fire premiums paid to a licensed London one.
7. A Cadillac and a definition of gift. Duberstein received a Cadillac after passing along business leads, and the donor deducted it. The Court asked whether the transfer came from “detached and disinterested generosity.” It did not. This was an income-tax exclusion case, not a gift-tax case.
8. The same payment, two answers. In NFIB (2012) the individual-mandate payment was not a “tax” for the Anti-Injunction Act yet was sustainable under the taxing power. A filing bar and a source of constitutional power ask different questions.
9. Wayfair’s majority crossed the usual lines. Justice Kennedy wrote for Justices Thomas, Ginsburg, Alito, and Gorsuch; the Chief Justice dissented with Justices Breyer, Sotomayor, and Kagan. A left–right label would have predicted neither side.
10. An estate-tax refund changed constitutional law. Edith Windsor paid $363,053 of federal estate tax because the Defense of Marriage Act denied her the marital deduction. Her refund suit ended with §3 of the Act struck down in 2013.
11. A Justice who had run the tax lawyers. Robert H. Jackson was general counsel of the Bureau of Internal Revenue from 1934 to 1936 and then led the Justice Department’s Tax Division. That is a different kind of evidence about tax expertise from any count of cases decided.

08 Research limits and next steps

Participation rewards service during a busy docket, and authorship counts reflect assignment practice. Neither tells us whose reasoning later courts adopted; an influence study would follow citations, later treatment, and statutory overrides, and would separate holdings from quotable dissents. Nor can a count tell a planner what the law is now. The PDF’s Appendix A flags the most important later development we found for each entry, but this edition checked holdings against the opinions; it did not run a citator over every case.

Before anyone calls this a census, four things remain: a written inclusion rule, logged for every entry; searches beyond the filters (adjudicating the 215 candidates, validating the benchmark itself, auditing excluded records, and adding full-text and independent-index searches); an audit by era and issue family, showing the 1946 source-file boundary; and pinpoints with a later-treatment check for every holding, dated.

What we would watch next

• The Pung remand. The Sixth Circuit will be handed Justice Sotomayor’s concurrence along with the opinion; its reading of “fairly conducted” will show how much work those words do.
• State surplus statutes. Legislatures that rewrote their tax-sale laws after Tyler will now test them against Pung’s auction-price baseline.
• CAPE and the Court of International Trade. Eligibility and deadlines for IEEPA refunds are still moving.
• Buy-sell agreements in estate audits. Expect Connelly to be applied to entity-owned policies. Families with insurance-funded redemption agreements should model both structures now.
• The next database release. Rerun the benchmark when the Supreme Court Database publishes a new release or revises existing records.

Our take

Hamilton promised a court with “neither FORCE nor WILL, but merely judgment.” On tax, that judgment has proved remarkably consequential. The Court checked Congress in Pollock and was itself checked by the Sixteenth Amendment. It checked a President in Learning Resources. In Pung it checked itself, declining to write a fair-market-value rule into the Constitution and leaving legislatures room to provide more. In Moore it upheld the tax before it and reserved the larger constitutional question for another day. Montesquieu would recognize the machine.

The count is worth having. It shows a Court whose recorded decisions were one-third tax and fiscal disputes at the 1931 peak and are a sliver today, and it shows the Justices who sat through the busiest years. It also shows its own limit: a database built to classify every decision cannot say which decisions are about tax, because the Court does not decide cases by tax label.

For clients, the value is in the holdings and their edges. Connelly did not say that insurance-funded buy-sell agreements fail; it said a fair-market-value redemption obligation does not offset the insurance. Moore neither blessed nor forbade a wealth tax; it sustained attribution of a foreign corporation’s realized income where Congress treated the corporation as a pass-through and the United States had not taxed it. Pung did not say every tax sale is fair; it said a fair sale sets the price. Each distinction is worth real money in the right file.

The uninvited party will be at the table for your next agreement, too. The market asks how many Supreme Court tax cases there are. The harder question, and the one that decides outcomes, is which of the Court’s propositions control the client’s facts, why they control, and whether later law has changed them.

A full selected case guide to 47 decisions (Appendix A), the complete counting tables and methodology (Appendices B–C), and the full annual series from 1791–2026 (Appendix D) are in the attached report.

Selected research and primary authorities

The founding. Montesquieu, The Spirit of Laws (1748), bk. XI, ch. 6 (Thomas Nugent trans. 1750), via The Founders’ Constitution, vol. 1, ch. 17, doc. 9 (University of Chicago Press); The Federalist Nos. 47 (Madison) and 78 (Hamilton), via Yale Law School’s Avalon Project; U.S. Const. art. I, §§7–8; art. III, §1; amend. XVI; Supreme Court of the United States, “The Court as an Institution”; ABA Journal, “February 2, 1790: Supreme Court Holds Inaugural Session.”

Supreme Court Database. Harold J. Spaeth, Lee Epstein, Andrew D. Martin, Jeffrey A. Segal, Theodore J. Ruger, and Sara C. Benesh, The Supreme Court Database, 2026 Release 01 (Sept. 7, 2026) and Legacy 07 (Oct. 1, 2021), with the online codebook.

Opinions and statutes. Each of the 47 decisions in Appendix A, linked to its official or Justia text; Marks v. United States, 430 U.S. 188, 193 (1977); United States v. Shipp, 203 U.S. 563 (1906) (contempt); Enochs v. Williams Packing & Navigation Co., 370 U.S. 1 (1962); South Carolina v. Regan, 465 U.S. 367 (1984); 18 U.S.C. §401; 28 U.S.C. §1651(a); 26 U.S.C. §7421(a); South Carolina v. Baker, 485 U.S. 505 (1988); Helvering v. Gregory, 69 F.2d 809, 810 (2d Cir. 1934) (L. Hand, J.).

Nancy C. Staudt, Lee Epstein, and Peter J. Wiedenbeck, The Ideological Component of Judging in the Taxation Context, 84 Wash. U. L. Rev. 1797, 1815–1816 (2006).

Congressional Research Service, Legal Sidebars LSB11185 (June 27, 2024) (Moore) and LSB11240 (Oct. 24, 2024) (Connelly).

Tariff refunds. U.S. Customs and Border Protection, CSMS message on the CAPE Phase 1 launch (Apr. 20, 2026) and CSMS #69035485 (June 23, 2026); Declaration of Brandon Lord, Freestyle World, Inc. v. CBP, No. 26-01088, ECF 50 (Ct. Int’l Trade Sept. 15, 2026); Holland & Knight, “CAPE Has Arrived: A Guide to Navigating the Next Phase of IEEPA Duty Refunds” (Apr. 2026); Thompson Hine, “CBP Issues Guidance on June 29, 2026 CAPE Expansion” (June 2026); C.H. Robinson client advisory (June 24, 2026); Cherry Bekaert, “IEEPA Tariff Refund Update: CAPE Phase III Set for October 6” (Sept. 2026).

Myron S. Scholes, Mark A. Wolfson, Merle Erickson, Michelle Hanlon, Edward L. Maydew, and Terry Shevlin, Taxes and Business Strategy, 5th ed., ch. 1, p. 20.

Important notes

Statutory references are to the Internal Revenue Code of 1986, as amended (the “Code”), and to Treasury regulations, each as in effect on the date of this report; “§” refers to a section of the Code unless a state or other federal statute is expressly identified.

Historical holdings are described as decided. Several have been overruled, superseded by statute, or limited; the PDF’s Appendix A flags the most important. Applying any case requires the current statute, regulations, later authorities, and the client’s facts. Opinions decided in 2026 are cited to the slip opinion.

All population figures use the 2,890-decision benchmark defined in Section 06 and the PDF’s Appendix C. The benchmark is not a census of substantive tax decisions. Figures are rounded. The tariff-refund guidance in Section 05 is current as of October 4, 2026, should be refreshed at release, and will change.

This client alert is for general information only. It is not tax, legal, investment, or accounting advice. Consult your own advisers about your particular circumstances before acting on any matter discussed here. Questions: Carlos Schmidt, CPA, carlos@lapresallc.com, (917) 558-6393.

C . A . S .

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This alert is for general information only and is not tax, legal, investment, or accounting advice. Consult your own advisers before acting. Carlos A. Schmidt, MBT, MBA, CPA · Managing Member · carlos@lapresallc.com · (917) 558-6393.