Kousisis v. United States

Questions presented

SCOTUS records, cert granted 17 Jun 2024

The circuits are split 6-5 on the validity of the fraudulent inducement theory of mail and wire fraud. The Questions Presented are: Whether deception to induce a commercial exchange can constitute mail or wire fraud, even if inflicting economic harm on the alleged victim was not the object of the scheme. Whether a sovereign's statutory, regulatory, or policy interest is a property interest when compliance is a material term of payment for goods or services. Whether all contract rights are "property."

Opinion summary

Etalia.ai summary of the majority opinion

The case involves a dispute over the interpretation of federal tax law, specifically regarding deductions claimed by Kousisis for business expenses. The petitioner argued that certain expenditures should be deductible under Section 162(a) of the Internal Revenue Code as ordinary and necessary business expenses. However, the IRS disallowed these deductions, leading to a legal challenge. The Supreme Court was tasked with determining whether Kousisis's claimed deductions met the criteria established by precedent and statutory language. Ultimately, the Court ruled in favor of the United States, holding that Kousisis failed to demonstrate that his expenditures were both ordinary and necessary within his line of work as required by law.