Hirsch v. United States Tax Court

(1) Whether the court of appeals must issue a writ of mandamus when a petitioner is erroneously denied a jury trial, without considering whether the right is clear or unambiguous or the petitioner has other potential avenues of relief; and (2) whether the Internal Revenue Code violates the Seventh Amendment and Article III by authorizing the IRS to order the payment of monetary penalties for fraud without providing the taxpayer a jury trial.