Tax returns of Donald Trump

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The tax returns of Donald Trump have been the subject of controversy for the past several years, particularly over their not having been made public despite his political career.

Before Trump announced his candidacy for president, he repeatedly promised to release his tax returns, making such pledges in 2011, 2014 ("absolutely") and 2015.[1][2] During his presidential campaign, Trump first said he would release his returns after they were "worked on.”[3] Then Trump claimed that, because the returns were being audited, he could not make them public, but would do so. No law actually prevents tax returns from being released due to an audit, as emphasized by the Commissioner of Internal Revenue.[4][5] Trump later said that voters were not interested in his returns; that "there's nothing to learn from them"; and that his tax rate is "none of your business".[2]

Since Trump's election, he has refused requests to release the returns, making him one of the few presidents in recent times to not reveal their tax returns. Trump was the first major party nominee since 1976 not to make his tax returns public. Several states have proposed bills that would require presidential candidates to release their tax returns in order to be listed on the 2020 ballot; such a bill was passed by the California Legislature and signed by Democratic Gov. Gavin Newsom.[6]

The Ways and Means Committee of the U.S. House of Representatives made a formal request to the Internal Revenue Service (IRS), and later issued a subpoena to the IRS, for six years of Trump's returns, as part of an effort by the committee to evaluate "the extent to which the I.R.S. audits and enforces the federal tax laws against a president."[7] Treasury Secretary Steven Mnuchin defied the subpoena.[8][9][10][11] Upon the Trump administration's refusal to turn over the documents, the Ways and Means Committee filed a suit to enforce the subpoena.[12][13] That case is pending.[14] A draft IRS legal memo, written in fall 2018 and reported in May 2019, concluded that the IRS must provide the requested tax returns to Congress unless Trump invokes executive privilege, contradicting the administration's justification for defying the earlier subpoena.[15]

Separately, the House Oversight Committee issued a subpoena to Trump's accounting firm for tax records and other records, as part of the committee's investigation into (1) whether Trump "may have engaged in illegal conduct before and during his tenure in office"; (2) whether Trump "has undisclosed conflicts of interest that may impair his ability to make impartial policy decisions"; (3) whether Trump was complying with the Constitution's Foreign Emoluments Clause and Domestic Emoluments Clause; and (4) whether Trump "has accurately reported his finances to the Office of Government Ethics and other federal entities."[16] Trump sued to block the subpoena; the U.S. District Court for the District of Columbia, and later the U.S. Court of Appeals for the District of Columbia, rejected Trump's position and have held that the subpoena must be complied with.[17][18][19]

In late August 2019, the Office of the New York County District Attorney issued a subpoena to Trump seeking eight years of his personal and corporate tax returns, as part of state prosecutors' investigation into hush-money payments made during the 2016 presidential election campaign.[20] Trump sought to quash the subpoena, contending that a sitting president enjoys "absolute immunity from criminal process of any kind."[20] In October 2019, Judge Victor Marrero of the U.S. District Court for the Southern District of New York rejected Trump's effort to prevent his tax returns from being turned over to the New York grand jury, and ordered Trump to comply with a subpoena. In a 75-page opinion, the court called Trump's contention an overreach of executive power that is "repugnant to the nation's governmental structure and constitutional values."[20][21] The U.S. Court of Appeals for the Second Circuit upheld the lower court's ruling in November 2019, rejecting Trump's claim that presidents are immune from state grand jury subpoenas.[22][23]

Separately, a New York state law was enacted in July 2019, authorizing New York state tax officials to release state tax returns, including Trump's, for any "specified and legitimate legislative purpose" to the House Ways and Means Committee and three other congressional committees.[24] Trump sued the State and the House Ways and Means Committee fifteen days later to block release of the tax returns.[25] In November 2019, Trump's suit was dismissed on jurisdictional grounds.[26]

Background

The IRS has stated that nothing prevents an individual from releasing their tax returns; an audit cannot stop the tax return release, and several former leaders of IRS have said that audits are a poor reason to justify not releasing tax returns. In any case, Trump has the ability to put on hold a current audit. Before Trump's election, every elected president from Richard Nixon onward has released their tax returns annually. While president, Nixon himself released his tax returns despite them being under audit. Also, all major presidential nominees from 1976 onward released their tax returns.[27]

Tax figures from 1985 through 1994

Trump lost $1.17 billion between 1985 and 1994 according to 10 years of Trump's tax information obtained by the New York Times, with the amount more than "nearly any other individual American taxpayer" during that period. Although Trump has acknowledged the tax-advantaged nature of the real estate business due to large depreciation write-offs to generate losses and reduce tax liabilities, the Times reported "depreciation cannot account for the hundreds of millions of dollars in losses."[28][29][30] Due to losing more than $500 million in combined losses, section 172 of the Omnibus Budget Reconciliation Act of 1993 gave Trump $915.7 million in tax exemption, which he used to pay off 8 years of taxes.[31][32][33]

Partially leaked returns of 1995 and 2005

Parts of Trump's 1995 and 2005 tax returns have been leaked.[34][35]

In October 2016, The New York Times published some tax documents from 1995. The New York Times reported that the Times had been given three pages of certain state tax returns for Trump for the year 1995. The materials indicated that Trump incurred a $916 million net operating loss which, for Federal income tax purposes, could have prevented Trump from owing any Federal income taxes for up to 18 years.[36] Marc Kasowitz of Kasowitz, Benson, Torres & Friedman wrote to the Times stating, according to one report, that "the publication of Trump's tax records was illegal because Trump had not authorized their disclosure ... [and] threatening 'prompt initiation of appropriate legal action.'"[37]

Trump claimed on his tax returns that he lost money, but did not recognize it in the form of canceled debts. Trump might have performed a stock-for-debt swap. This would have allowed Trump to avoid paying income taxes for at least 18 years. An audit of Trump's tax returns for 2002 through 2008 was "closed administratively by agreement with the I.R.S. without assessment or payment, on a net basis, of any deficiency." Tax attorneys believe the government may have reduced what Trump was able to claim as a loss without requiring him to pay any additional taxes.[38][39] It is unknown whether the I.R.S. challenged Trump's use of the swaps because he has not released his tax returns. Trump's lawyers advised against Trump using the equity for debt swap, as they believed it to be potentially illegal.[40]

On March 14, 2017, the first two pages of Trump's 2005 federal income tax returns were leaked to Rachel Maddow and shown on MSNBC. The document states that Trump had a gross adjusted income of $150 million and paid $38 million in federal taxes. The White House confirmed the authenticity of these documents and claimed: "Despite this substantial income figure and tax paid, it is totally illegal to steal and publish tax returns."[41][42].

Before his presidency

In 1999, while Trump was considering whether to run for president under the Reform Party, he said "probably wouldn't have a problem with" releasing his tax returns if he ran.[43]

In April 2011, Trump said that when President Barack Obama produces "his birth certificate ... I’d love to give my tax returns". Obama's birth certificate was released a week later, resulting in Trump saying his tax returns would be released "at the appropriate time".[1]

In 2012, Trump implored for Republican presidential candidate Mitt Romney's tax returns to be released on April 1, which "historically is the time that everybody gives them".[27] That year, Trump also said that not seeing a presidential candidate's tax returns would lead people to think there was "almost, like, something wrong. What's wrong?"[44]

According to Trump's former political adviser Sam Nunberg and another former Trump adviser, in 2013 and 2014, Trump had considered the possibility of releasing his tax returns as part of a presidential campaign, believing that showing how little he paid in taxes would make him appear to be a savvy businessman.[45] Nunberg said by November 2014, he had persuaded Trump to reverse course and withhold his tax returns, as Trump decided that he "wanted to look rich rather than smart."[45]

In May 2014, Trump said in an interview: "If I decide to run for office, I’ll produce my tax returns, absolutely and I would love to do that."[1]

In February 2015, Trump said that if he ran for the presidency: "I would release tax returns".[1] On another occasion that month, he declared: "I have no objection to certainly showing tax returns".[46]

Also in February 2015, Trump warned: "I will tell you upfront ... I want to pay as little taxes as I can as a private person".[1] In May 2016, Trump voiced similar sentiments, stating he tries "very hard to pay as little tax as possible". However, Trump has in 2015 criticized corporate executives and "hedge fund guys" for paying zero or negligible taxes. He also alleged in 2011 and 2012 that half of all Americans do not pay income taxes, stating: "it's a problem", while noting "crippling" government debt. Trump also in 2012 criticized President Barack Obama for "only" paying a tax rate of around 20%.[27]

Trump announced his candidacy for President in June 2015.[47]

In January 2016, Trump was asked by Chuck Todd if he would release his tax returns. Trump answered: "we'll be working that over in the next period of time, Chuck. Absolutely. [...] at the appropriate time, you'll be very satisfied."[3]

In February 2016, Trump said that he would release his tax returns "[p]robably over the next few months. They’re being worked on now."[3]

Also in February 2016, Trump said that he could not release his tax returns because he was under audit.[48] Trump has elaborated that he has been audited for a consecutive "twelve years or something like that."[48] In 2016, Trump's tax attorneys have stated that Trump has been under audit since 2002. However, in 2011, 2014, and 2015, Trump made offers to release his tax returns, presumably while he was still under audit.[1]

The IRS commissioner at the time, John Koskinen, said that an IRS audit does not prevent the taxpayer from releasing tax returns. Koskinen also said that it "would be rare for anyone to be audited every year", and that if a past audit revealed no problems, "it’s a number of years — two or three at least" before the IRS would conduct an audit again.[48][48][49]

There is no requirement that presidential candidates release their tax returns but candidates are legally free to do so even when under audit.[50][51] Tax lawyers differ as to whether releasing tax returns is legally advisable for someone like Trump who has stated he is under audit.[51][52] According to NPR, tax experts, such as New York University Law School professor Daniel Shaviro, say that "Trump's lawyers may advise him not to release the returns for legal strategy purposes."[53] In contrast, economist Paul Krugman argued that Trump should be more willing to reveal his tax information if he were already under audit, as the reveal might have triggered an audit if there was not one.[54]

In May 2016, Trump said that he did not plan to release his tax returns before the November 2016 election;[55] the tax returns were not released.[56] Trump also said in May 2016 that "there's nothing to learn from" his tax returns,[55] and said on ABC News that his tax rate is "none of your business".[2]

Trump was criticized for his refusal to release tax information. Former Republican presidential candidate Mitt Romney said, "It is disqualifying for a modern-day presidential nominee to refuse to release tax returns to the voters." Romney speculated, "There is only one logical explanation for Mr. Trump's refusal to release his returns: there is a bombshell in them."[57] John Fund of the National Review said that Republican convention delegates should abstain from voting for Trump if he does not release the information, fearing that the returns could contain an electoral "time bomb".[58]

During the 2016 United States presidential debates, rival presidential candidate Hillary Clinton criticized Trump, saying that only "a couple of years" of Trump's tax returns were publicly available, "and they showed he didn't pay any federal income tax". Trump directly responded: "That makes me smart." Clinton went on to suggest that Trump might not have "paid any federal income tax for a lot of years"; this resulted in Trump saying that the taxes he paid "would be squandered" by the government.[59]

During his presidency

Trump has continued to withhold his tax returns even into his presidency as of September 2019.[56]

In May 2017, Trump said that he "might" release his tax returns only after he had stepped down as President. This was in spite of his previous commitment made during his campaign to release his tax returns once they were not under audit.[60]

Tax March protests

In January 2017, an online petition on the "We the People" portion of the White House's website calling for the release of Trump's tax returns was set up.[61] The petition gained over 1 million signatures, becoming the most signed petition on the White House's website. However, the White House gave no official response to the petition as of April 2017.[62] Trump spokesperson Kellyanne Conway then said that "The White House response is that he’s not going to release the tax returns" and that "people didn't care" about Trump's tax returns.[63] In response, Jennifer Taub and others planned the Tax March on April 15, 2017 (Tax Day) to demand that Trump release his tax returns;[64] tens of thousands of people marched in New York and dozens of cities across the country.[65][66]

Congressional requests and subpoenas for Trump's tax returns

After winning control of the House in the 2018 elections, House Democrats signaled their intent to use their new power to demand Trump's tax returns in the new Congress, which convened in January 2019.[67][68][69] In April 2019, the chairman of the United States House Committee on Ways and Means, Congressman Richard Neal, formally requested from the IRS six years of Trump's returns.[70][71] The last time a sitting president's tax information was requested was 45 years ago.[70] The request was made on April 3 via a letter to IRS Commissioner Charles Rettig. It requested both Trump's business and personal returns for the years 2013 through 2018. The deadline he set was April 10, seven days later.[70] After the first deadline was not met, Neal again wrote to Rettig on April 13, setting a second deadline of April 23, 2019, and writing that a failure to meet the deadline would be "interpreted as a denial".[72]

Under a 1924 federal tax law, § 6103 of title 26 of the United States Code, Congress may request copies of anyone's tax returns.[73][74][75][76] The treasury secretary is legally obliged to provide the tax returns, and there is no apparent legal mechanism to deny Congress's request.[77] On April 5, 2019, Trump's personal lawyer William Consovoy wrote a letter to the United States Department of the Treasury (the parent agency of the IRS), claiming that the request for Trump's tax information is "not consistent with governing law" and that Congress is trying to violate Trump's First Amendment rights.[78]

House committees issue formal subpoenas for tax records

On April 15, 2019, the chairman of the House Committee on Oversight and Reform, Representative Elijah Cummings, issued a subpoena to the accounting firm Mazars USA, LLP requesting tax records and other "financial documents concerning the President and his companies covering years both before and during his presidency."[16] Cummings identified four areas that the committee aimed to investigate through the subpoena: (1) whether Trump "may have engaged in illegal conduct before and during his tenure in office"; (2) whether Trump "has undisclosed conflicts of interest that may impair his ability to make impartial policy decisions"; (3) whether Trump was complying with the Constitution's Foreign Emoluments Clause and Domestic Emoluments Clause; and (4) whether Trump "has accurately reported his finances to the Office of Government Ethics and other federal entities."[16]

On May 10, 2019, Neal, the chairman of the House Ways and Means Committee, issued a separate subpoena to both the Treasury Department and Internal Revenue Service to hand over six years of President Trump's personal and business tax returns and grant access by May 17.[7] Neal stated that the committee aimed to obtain the tax records to evaluate "the extent to which the I.R.S. audits and enforces the federal tax laws against a president."[7]

Trump administration defies subpoenas

The Trump administration refused to comply with the subpoenas.[79][80] On May 6, 2019, after weeks of delay, Treasury Secretary Steven Mnuchin sent a letter to House Ways and Means Committee chair Neal, asserting that the subpoena lacked "a legitimate legislative purpose" and that "the department may not lawfully fulfill the committee's request," although the IRS released president Richard Nixon's tax returns the same day Congress requested them in 1973.[80] The Trump's administration's Justice Department, through a memo written by Office of Legal Counsel head Steven Engel, issued an opinion supporting Mnuchin's refusal to release Trump's tax returns.[81] This triggered a legal battle between the administration and Congress.[82][83][84][85] Neal criticized the administration's position, saying that its objections "lack merit" and that "judicial precedent commands that none of the concerns raised can legitimately be used to deny the committee’s request."[86]

On April 7, 2019, Mick Mulvaney, Trump's acting White House Chief of Staff, said that Trump's tax returns will "never" be released.[87][88] Trump and Mulvaney have argued that voters have no interest in Trump's tax returns and that the issue was "litigated" when Trump was elected to the presidency.[87][89]

On May 7, 2019, The New York Times revealed that it had acquired information about Trump's tax returns showing over one billion dollars in business losses with a decade in the red.[28][90]

In April 2019, a Trump adviser speaking on condition of anonymity told Fox News that Trump has repeatedly questioned his aides about the status of the congressional request, and also asked about the "loyalty" of top IRS officials.[89] Trump appointee Michael J. Desmond, who as Chief Counsel of the IRS and Assistant General Counsel in the Department of the Treasury is responsible for giving legal advice to the IRS Commissioner, previously served as a tax advisor to the Trump Organization and also worked alongside two other longtime tax advisors to the Trump Organization. According to the New York Times, on February 5, 2019, Trump asked Senate Majority Leader Mitch McConnell to speed up Desmond's confirmation and indicating that confirming Desmond was a higher priority to him than confirming William Barr for Attorney General.[91]

Trump and his White House Press Secretary, Sarah Sanders, said that Trump would not release his tax returns while they are under audit,[77] although nothing precludes a person from releasing tax returns that are under audit,[77] a fact reaffirmed by IRS Commissioner Rettig.[92] Sanders also opined that Congress is not "smart enough" to examine Trump's tax returns,[93] although ten members of Congress are accountants, including three Certified Public Accountants.[94]

On April 10, Trump made a partially false statement that "There’s no law whatsoever" that requires him to provide Congress his tax returns. While there is no law requiring Trump to publicly release his tax returns, federal law of IRS Code section 6103(f) does require Trump's (or anyone else's) tax returns to be given to Congress if they request it.[95][96]

Trump's efforts in court to block House subpoenas

House Ways and Means Committee's suit to enforce subpoena to IRS

On May 17, 2019, Treasury Secretary Mnuchin again refused to hand over the records.[79] On July 2, 2019, the House Committee on Ways and Means sued Mnuchin and IRS Commissioner Rettig to enforce the subpoena and obtain six years of Trump's tax returns.[12][13] The suit is pending before U.S. District Judge Trevor McFadden, a Trump appointee, in the U.S. District Court for the District of Columbia.[14] In September 2019, a bipartisan group of six former general counsels to the House of Representatives filed an amicus brief in the case, urging the court to reject Trump's claims that the House lacks standing to bring the case.[14]

Trump v. Mazars USA, LLP: Trump's efforts to block House Oversight Committee subpoena to accounting firm

On May 20, 2019, U.S. District Judge Amit Mehta of the U.S. District Court for the District of Columbia, refused a request by Trump's attorneys to quash the subpoena from the House Oversight Committee directed to Trump's accounting firm, Mazars USA LLP, ruling that the subpoena must be complied with.[97][17] The district court held that the subpoena was well within Congress's broad investigative powers and rejected Trump's claim that the subpoena to Mazars was "a usurpation of an exclusively executive or judicial function."[17]

Trump then appealed to the U.S. Court of Appeals for the District of Columbia, which heard oral argument on July 12, 2019, and then issued a ruling against Trump on October 11, 2019. In its 2–1 ruling, the court of appeals upheld the lower court's ruling, holding that "contrary to the President's arguments, the Committee possesses authority under both the House Rules and the Constitution to issue the subpoena" for eight years of tax returns to Mazars, and that Mazars therefore "must comply" with the subpoena.[18][19] The 66-page majority opinion was written by Judge David S. Tatel, joined by Patricia A. Millett; Judge Neomi Rao, a Trump appointee, dissented.[18] Trump's motion for rehearing en banc (i.e., before the entire D.C. Circuit) was denied on November 13, 2019, on an 8–3 vote.[98][99] The ruling was the second appeals court decision within ten days against Trump regarding release of his tax returns.[98]

Trump subsequently filed a petition for a writ of certiorari to the Supreme Court of the United States, asking the Court to review the case. On December 13, 2019, the Supreme Court decided to review both the Trump v. Mazars US, LLP case (Supreme Court No. 19-715) and the Trump v. Deutsche Bank AG case (Supreme Court number 19-760). The court consolidated both cases and indicated that the cases would be set for oral argument sometime in the March 2020 argument session.[100][101] The Second Circuit's mandate was stayed pending the Supreme Court's decision in the case.[101][102] The Court's decision in the case is believed to be a likely landmark ruling on how far presidents may resist subpoenas or other demands for information from the Congress and from prosecutors.[100]

California primary election law

On July 30, 2019, California governor Gavin Newsom signed the Presidential Tax Transparency and Accountability Act (S.B. 27), a law requiring candidates for president and California governor, as a condition for gaining California ballot access, to release their most recent five years of federal tax returns at least 98 days ahead of the primary election (which would be November 26, 2019, for the 2020 primaries, since the California primary is on March 3, 2020).[103][104][105]

Trump immediately sued the State of California, seeking to block implementation of the law, asserting that the law is unconstitutional.[106] On September 19, 2019, U.S. District Judge Morrison C. England issued a temporary injunction blocking the law from taking effect.[106] California appealed; California Secretary of State Alex Padilla said: "Our elected leaders have a legal and moral obligation to be transparent with voters about potential conflicts of interest. This law is fundamental to preserving and protecting American democracy."[107] In December 2019, the U.S. Court of Appeals for the Ninth Circuit dismissed California's appeal of the federal district court decision as moot, in light of the California Supreme Court's decision (see below).[108]

The law was separately challenged in state court, and in November 2019, the California Supreme Court unanimously invalidated the law, meaning that Trump will not have to release his tax returns to get on the primary ballot in California in 2020.[103][109] Chief Justice Tani Gorre Cantil-Sakauye wrote that "The Legislature may well be correct that a presidential candidate's income tax returns could provide California voters with important information" but that the requirement to release the returns conflicted with the California Constitution's "specification of an inclusive open presidential primary ballot."[103]

New York TRUST Act

In May 2019, the New York State Senate passed the TRUST Act which would amend state law to permit the commissioner of the state Department of Taxation and Finance to release any state tax return requested by the leaders of the House Ways and Means Committee, the Senate Finance Committee or the Joint Committee on Taxation for any "specific and legitimate legislative purpose."[110][111] The New York State Assembly approved the bill on May 22, sending it to the governor.[112] On July 8 Gov. Andrew M. Cuomo signed the bill.[24]

Trump sued the State and the House Ways and Means Committee fifteen days later to block release of the tax returns.[25] In November 2019, Trump's suit was dismissed on personal jurisdiction grounds.[26]

Trump v. Vance: Trump's challenge to Manhattan district attorney subpoena

In late August 2019,[20] soon after opening an investigation into hush-money payments to Stormy Daniels, the Manhattan district attorney's office issued a subpoena to Trump's accounting firm, Mazars USA, for eight years of Trump's individual tax returns and corporate tax records for the Trump Organization.[20][113] The existence of the subpoena was first reported by the New York Times in September 2019.[113]

Trump sought to quash the subpoena in federal court, contending that a sitting president enjoys "absolute immunity from criminal process of any kind."[20] In court filings in September 2019, New York prosecutors rejected Trump's claim that he has "sweeping immunity" from a criminal probe while he is in office, writing that Trump was "seeking to invent and enforce a new presidential 'tax return privilege,' on the theory that disclosing information in a tax return will necessarily reveal information that will somehow impede the functioning of a President, sufficiently to meet the test of irreparable harm."[114][115]

On October 7, 2019, Judge Victor Marrero of the U.S. District Court for the Southern District of New York rejected Trump's effort to prevent his tax returns from being turned over to the New York grand jury, and ordered Trump to comply with a subpoena. In a 75-page opinion, the court called Trump's contention an overreach of executive power that is "repugnant to the nation's governmental structure and constitutional values."[20][21] Enforcement of the subpoena was temporarily delayed pending consideration by the U.S. Court of Appeals for the Second Circuit.[20][116] Later the same month, oral argument before the Second Circuit took place before a three-judge panel of Chief Judge Robert A. Katzmann, Judge Denny Chin, and Judge Christopher F. Droney. Trump's private lawyer, William S. Consovoy, argued that a president enjoyed absolute "presidential immunity" from all investigation and criminal process while in office; responding to a hypothetical from the court, Consovoy said the president should be shielded even if he hypothetically committed murder on Fifth Avenue in Manhattan.[117][118][119] In response, counsel for the Manhattan District Attorney's Office told the court that "there is no such thing as presidential immunity for tax returns" and noted that tax returns are frequently subpoenaed in financial investigations.[117]

On November 4, 2019, a three-judge panel of the Second Circuit unanimously ruled that Mazars must comply with the subpoena and hand over eight years of Trump's tax returns.[22][23] The court held that the president is not immune from "the enforcement of a state grand jury subpoena directing a third party to produce non-privileged material, even when the subject matter under investigation pertains to the President" and that a state grand jury may permissibly issue subpoenas "in aid of its investigation of potential crimes committed by persons within its jurisdiction, even if that investigation may in some way implicate the President."[23] Noting that "the President concedes that his immunity lasts only so long as he holds office and that he could therefore be prosecuted after leaving office," the Second Circuit ruled that there "is no obvious reason why a state could not begin to investigate a President during his term and, with the information secured during that search, ultimately determine to prosecute him after he leaves office."[23]

Trump subsequently filed a petition for a writ of certiorari to the Supreme Court, asking the Court to review the case; Trump asserts that the grand-jury subpoena directed to him violates Article II and the Supremacy Clause of the Constitution. In December 2019, the Court agreed to hear the case, and indicated that oral arguments would be heard in the March 2020 argument session.[120]

Whistleblower complaint regarding interference in mandatory IRS audit process

On July 29, 2019, a career IRS official filed a whistleblower complaint with the House Ways and Means Committee, Senate Finance Committee, and Treasury Inspector General for Tax Administration, stating that at least one Treasury Department official had inappropriately interfered in the audit process for the tax returns of the president and vice president,[121] which takes place annually in accordance with IRS policy.[122] The possibility that political appointees interfered with audits conducted by career civil servants alarmed former IRS officials and legal experts.[121] Due to stringent laws regarding disclosure of tax information, the details of the complaint have not been made public.[121] However, Representative Richard E. Neal, the Democratic chair of the House Ways and Means Committee, said in September 2019 that he was consulting legal counsel on whether the whistleblower's complaint could be publicly released.[123]

The whistleblower's report was referred to by Neal and other House Democrats in the federal lawsuit regarding Trump's refusal to comply with a House Ways and Means Committee subpoena for the returns; in a filing, Neal wrote that the whistleblower's complaint presents credible evidence of "potential 'inappropriate efforts to influence' the mandatory audit program" and raises "serious and urgent concerns," thereby bolsters the committee's case for obtaining the tax returns.[124]

See also

References

  1. 1.0 1.1 1.2 1.3 1.4 1.5 Qiu, Linda. "Pence's False claim that Trump 'hasn't broken' tax return promise". Politifact. Retrieved April 11, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  2. 2.0 2.1 2.2 Harwell, Drew (May 21, 2016). "Trump once revealed his income tax returns. They showed he didn't pay a cent". The Washington Post. Archived from the original on July 6, 2016. Retrieved July 18, 2016.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  3. 3.0 3.1 3.2 Blake, Aaron. "5 things Donald Trump promised he'd do, but hasn't". The Washington Post. Retrieved April 19, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  4. Davison, Laura; Talev, Margaret. "Trump Falsely Says Law Prevents Him Releasing Tax Returns Under Audit". Bloomberg News. Retrieved April 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  5. Rummler, Orion (April 10, 2019). "IRS commissioner: No rule against releasing Trump's tax returns while under audit". Axios.com. Retrieved April 11, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  6. White, Jeremy (July 30, 2019). "California's Newsom signs bill to force Trump tax returns". Politico. Retrieved August 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  7. 7.0 7.1 7.2 Fandos, Nicholas (May 10, 2019). "House Ways and Means Chairman Subpoenas Trump Tax Returns". New York Times.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  8. Uria, Daniel. "Mnuchin: Treasury to make 'final decision' on Trump tax returns May 6". United Press International. Retrieved April 28, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  9. Rappeport, Alan (May 6, 2019). "Steven Mnuchin Refuses to Release Trump's Tax Returns to Congress". The New York Times. Retrieved May 7, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  10. Fandos, Nicholas (May 10, 2019). "House Ways and Means Chairman Subpoenas Trump Tax Records". NYTimes.com.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  11. Rubin, Richard (May 17, 2019). "Mnuchin Defies Subpoena for President Trump's Tax Returns". Wall Street Journal.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  12. 12.0 12.1 Kelsey Snell (July 2, 2019). "House Democrats Sue For Trump's Tax Returns". NPR. Retrieved July 2, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  13. 13.0 13.1 Quinta Jurecic, House Ways and Means Committee Sues for Trump Tax Returns, Lawfare (July 2, 2019).
  14. 14.0 14.1 14.2 Jacqueline Thomsen, 'The Obvious Answer': Ex-House Attorneys Back Democrats' Lawsuit for Trump Tax Returns, National Law Journal (September 20, 2019).
  15. "Confidential draft IRS memo says tax returns must be given to Congress unless president invokes executive privilege". Washington Post. May 21, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  16. 16.0 16.1 16.2 Trump v. Mazars USA, No. 19-5142 (D.C. Cir. Oct. 11, 2019).
  17. 17.0 17.1 17.2 Trump v. Committee on Oversight & Reform of U.S. House of Representatives, 380 F. Supp. 3d 76 (D.D.C. 2019).
  18. 18.0 18.1 18.2 David A. Fahrenthold, Spencer S. Hsu & Ann E. Marimow, Appeals court rules against Trump in fight with Congress over president’s accounting firm records, Washington Post (October 11, 2019).
  19. 19.0 19.1 Daniel Hemel, How Trump can put off his tax return case until after the election, Washington Post (October 14, 2019).
  20. 20.0 20.1 20.2 20.3 20.4 20.5 20.6 20.7 Rashbaum, Weiser (October 7, 2019). "Trump Taxes: President Ordered to Turn Over Returns to Manhattan D.A." The New York Times.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  21. 21.0 21.1 Trump v. Vance, 395 F. Supp. 3d. court=S.D.N.Y..
  22. 22.0 22.1 Benjamin Weiser & Adam Liptak, Trump Taxes: Appeals Court Rules President Must Turn Over 8 Years of Tax Returns, New York Times (November 4, 2019).
  23. 23.0 23.1 23.2 23.3 Trump v. Vance (2d Cir. Nov. 4, 2019).
  24. 24.0 24.1 McKinley, Jesse; Fandos, Nicholas (July 8, 2019). "Cuomo Signs a Bill to Allow Release of Trump's State Tax Returns". The New York Times.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  25. 25.0 25.1 Fandos, Nicholas; McKinley, Jesse (July 23, 2019). "Trump Sues New York and Congress to Shield His State Tax Returns". New York Times.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  26. 26.0 26.1 Katelyn Polantz, Trump can't sue New York state in DC federal court to stop release of tax returns, judge says, CNN (November 11, 2019).
  27. 27.0 27.1 27.2 Harwell, Drew (September 15, 2016). "All the excuses Trump has given for why he won't release his tax returns". Washington Post. Retrieved August 7, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  28. 28.0 28.1 Buettner, Russ; Craig, Susanne (May 7, 2019). "Decade in the Red: Trump Tax Figures Show Over $1 Billion in Business Losses". The New York Times. Retrieved May 7, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  29. Buettner, Russ; Craig, Susanne (May 7, 2019). "5 Takeaways From 10 Years of Trump Tax Figures". The New York Times. Retrieved May 8, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  30. Calia, Mike (May 8, 2019). "Trump defends tax tactics after NYT probe says he racked up more than $1 billion in losses: 'It was sport'". CNBC. Retrieved May 8, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  31. Craig, Susanne; Buettner, Russ (May 7, 2019). "5 Takeaways From 10 Years of Trump Tax Figures". The New York Times. ISSN 0362-4331. Retrieved May 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  32. Sabo, Martin Olav (August 10, 1993). "Text - H.R.2264 - 103rd Congress (1993-1994): Omnibus Budget Reconciliation Act of 1993". Congress.gov. Retrieved May 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  33. Fahrenthold, David A. (May 5, 2019). "Trump's early financial losses were so steep that he did not pay income taxes for eight years, according to new report". The Washington Post. Retrieved May 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  34. Doe, John (October 1, 2016). "Trump incurrs $916 million loss on his income tax returns". CBS News. Archived from the original on October 2, 2016. Retrieved October 2, 2016.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  35. "A Trump tax return revealed -- here's what accountants think of it". cbsnews.com. Archived from the original on September 29, 2018. Retrieved April 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  36. Doe, John (October 1, 2016). "Trump incurrs $916 million loss on his income tax returns". CBS News. Archived from the original on October 2, 2016. Retrieved October 2, 2016.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  37. Zaretsky, Staci, "Donald Trump Chooses Biglaw Firm To Fight New York Times Over Publication Of Tax Documents" 17, 2018/https://web.archive.org/web/20180617093028/https://abovethelaw.com/2016/10/donald-trump-chooses-biglaw-firm-to-fight-new-york-times-over-publication-of-tax-documents/ Archived June 17, 2018 at the Wayback Machine, Above the Law, October 3, 2016. Retrieved January 17, 2017.
  38. "A big, dirty secret from Donald Trump's tax returns has been exposed" 10, 2019/https://web.archive.org/web/20190210192856/https://www.washingtonpost.com/news/wonk/wp/2016/11/01/a-big-dirty-secret-from-donald-trumps-tax-returns-has-been-exposed/ Archived February 10, 2019 at the Wayback Machine. The Washington Post. November 1, 2016. Retrieved November 2, 2016.
  39. "How a Simple Tax Rule Let Donald Trump Turn a $916 Million Loss Into a Plus" 9, 2018/https://web.archive.org/web/20181209120846/https://www.nytimes.com/2016/10/04/us/politics/donald-trump-taxes.html Archived December 9, 2018 at the Wayback Machine. The New York Times. October 4, 2016. Retrieved November 2, 2016.
  40. "Avoiding Taxes, Trump-Style" 20, 2018/https://web.archive.org/web/20181220230939/https://www.nytimes.com/2016/11/02/opinion/avoiding-taxes-trump-style.html Archived December 20, 2018 at the Wayback Machine. The New York Times. November 2, 2016. Retrieved November 2, 2016.
  41. Baker, Peter; Drucker, Jesse; Craig, Susanne; Barstow, David (March 15, 2017). "Trump Wrote Off $100 Million in Business Losses in 2005". The New York Times. Retrieved March 15, 2017.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  42. Jagoda, Naomi. "WH releases Trump tax info ahead of MSNBC report: He paid $38M in federal taxes in '05". The Hill. Retrieved March 15, 2017.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  43. Kaczynski, Andrew (March 4, 2016). "Trump In 1999: I Probably Wouldn't Have A Problem Releasing My Tax Returns If I Ran". Buzzfeed News. Retrieved August 7, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  44. Kelly, Nora (August 12, 2016). "How Hillary Clinton Is Using Her Taxes as a Political Weapon". The Atlantic. Retrieved August 7, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  45. 45.0 45.1 Vicky Ward, Trump wanted to release his taxes in 2013 to show how smart he was for paying so little, CNN (October 14, 2019).
  46. Gass, Nick (June 5, 2016). "Carson: Trump will release tax returns before election". Politico. Retrieved August 7, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  47. Santucci, John; Stracqualursi, Veronica. "Donald Trump Announces 2016 Presidential Campaign: 'We Are Going Make our Country Great Again'". ABC News. Retrieved April 19, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  48. 48.0 48.1 48.2 48.3 Becker, Bernie; Faler, Brian. "IRS chief: 'Rare' for taxpayer to be audited several years in a row, as Trump claims". Politico. Retrieved April 11, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  49. "IRS Commissioner: Trump Can Release His Tax Returns". PJ Media. Archived from the original on October 13, 2018. Retrieved April 5, 2019. IRS Commissioner John Koskinen said Republican presidential frontrunner Donald Trump is able to release his tax returns despite the audit that's being conducted.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  50. Alan Rappeport (May 11, 2016). "Donald Trump Breaks With Recent History by Not Releasing Tax Returns". The New York Times. Archived from the original on January 6, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  51. 51.0 51.1 Stockman, Rachel (May 13, 2016). "Legal Experts Side With Trump; It Would Be Crazy to Release His Taxes During Audit". Law Newz. Archived from the original on July 16, 2016. Retrieved July 19, 2016.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  52. Stewart, Emily. "Would No Tax Lawyer Advise Trump Release His Tax Returns? It's Complicated" 24, 2016/https://web.archive.org/web/20160924183723/https://www.thestreet.com/story/13687015/1/would-no-tax-lawyer-advise-trump-release-his-tax-returns-it-s-complicated.html Archived September 24, 2016 at the Wayback Machine, TheStreet.com (August 27, 2016).
  53. Zarroli, Jim. "Fact-Check: Donald Trump Can't Release His Taxes While Being Audited?" 2, 2019/https://web.archive.org/web/20190302140445/https://www.npr.org/2016/02/26/468278769/fact-check-donald-trump-cant-release-his-taxes-while-being-audited Archived March 2, 2019 at the Wayback Machine, NPR (February 26, 2016).
  54. "The saga over Donald Trump's tax returns rolls on". The Economist. June 1, 2016. Archived from the original on July 14, 2016. Retrieved July 18, 2016.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  55. 55.0 55.1 Rappeport, Alan (May 11, 2016). "Donald Trump Breaks With Recent History by Not Releasing Tax Returns". The New York Times. Archived from the original on July 19, 2016. Retrieved July 18, 2016.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  56. 56.0 56.1 "Will Donald Trump's Tax Returns Be Released? Democrats Just Made Their First Move". Money. Archived from the original on February 17, 2019. Retrieved April 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  57. "Romney calls decision by Trump not to release tax returns 'disqualifying'". Fox News. May 11, 2016. Archived from the original on June 19, 2016. Retrieved July 18, 2016.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  58. Fund, John (May 11, 2016). "Trump's Refusal to Release Tax Returns Is a Ticking Time Bomb for the GOP". National Review. Archived from the original on July 18, 2016. Retrieved July 18, 2016.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  59. Mangan, Dan. "Trump brags about not paying taxes: 'That makes me smart'". CNBC. Retrieved April 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  60. "Release his tax returns after an audit is completed - Trump-O-Meter: Broken". Politifact. Retrieved April 11, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  61. Ellis, Emma Grey (January 26, 2017). "A Petition Didn't Make Trump Give Up His Tax Returns—But It Made Him Listen". WIRED. Archived from the original on January 28, 2017. Retrieved January 31, 2017.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  62. Lam, Bourree. "The Fight Over Trump's Tax Returns Isn't Over". The Atlantic. Retrieved April 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  63. Revesz, Rachel (January 22, 2017). "Kellyanne Conway says President Trump will not release his tax returns". The Independent. Retrieved October 7, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  64. Amber Jamieson, Tax March: how a law professor sparked a global event to demand Trump's returns, The Guardian (April 12, 2017).
  65. "Tax March" protests demand release of Trump's tax returns, CBS News/Associated Press (April 15, 2017).
  66. Francescani, Chris; Ramstack, Tom (April 15, 2017). "Thousands at rallies demand Trump release tax returns". Reuters.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  67. "With House majority, Dems intend to request Trump's tax returns". MSNBC.com. Archived from the original on February 18, 2019. Retrieved April 6, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  68. Porter, Tom (November 7, 2018). "Democrats set to demand Donald Trump's tax returns after winning House majority". Newsweek. Archived from the original on March 28, 2019. Retrieved April 6, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  69. "Once in power, House Democrats will reportedly demand Trump's tax returns". theweek.com. November 6, 2018. Archived from the original on February 7, 2019. Retrieved April 6, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  70. 70.0 70.1 70.2 Gordon, Marcy (April 4, 2019). "White House pushes back on request for Trump tax forms". Associated Press. Archived from the original on April 5, 2019. Retrieved April 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  71. "White House maneuvers to block release of Trump's tax returns". Washington Post. Archived from the original on April 5, 2019. Retrieved April 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  72. Lorenzo, Aaron. "Neal gives IRS commissioner new deadline for handing over Trump's tax returns". Politico. Retrieved April 19, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  73. "Here's how Democrats plan to get Donald Trump's tax returns". NBC News. Archived from the original on January 18, 2019. Retrieved April 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  74. Harmon, John M. (May 2, 1977). "Memorandum Opinion for the Acting Commissioner of the Internal Revenue Service - Congressional Access to Tax Returns—26 U.S.C. § 6103(f)" (PDF). United States Department of Justice. Retrieved April 4, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  75. "26 U.S. Code § 6103 - Confidentiality and disclosure of returns and return information". Legal Information Institute. Archived from the original on April 1, 2019. Retrieved April 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  76. Sahadi, Jeanne. "The 1924 law Democrats may tap to see Trump's tax returns". CNN. Archived from the original on March 7, 2019. Retrieved April 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  77. 77.0 77.1 77.2 "White House maneuvers to block release of Trump's tax returns". Washington Post. Archived from the original on April 5, 2019. Retrieved April 5, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  78. Campbell, Andy; Delaney, Arthur (April 5, 2019). "Trump Lawyers Fight Release Of The President's Tax Returns". HuffPost.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  79. 79.0 79.1 Lauren Fox (May 17, 2019). "Mnuchin defies House Democrats' subpoenas for Trump's tax returns". CNN.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  80. 80.0 80.1 Rappeport, Alan (May 6, 2019). "Steven Mnuchin Refuses to Release Trump's Tax Returns to Congress". The New York Times. Retrieved May 7, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  81. Rappeport, Alan (June 14, 2019). "Justice Dept. Backs Mnuchin's Refusal to Release Trump's Tax Returns". The New York Times. Retrieved June 17, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  82. Andrew Taylor & Jonathan Lemire, Refusal to hand over Trump’s tax returns sets up legal fight, Associated Press (May 7, 2019).
  83. "Mnuchin rejects Democrats' demand to hand over Trump's tax returns, all but ensuring legal battle". Washington Post.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  84. "Justice Dept. issues memo backing Mnuchin's refusal to give Trump's tax returns to Congress". Washington Post.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  85. "IRS turned over Nixon's tax returns the same day that a congressional panel asked for them". Washington Post.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  86. Stein, Jeff. "House Democrats give IRS hard deadline of April 23 to turn over Trump tax returns, say administration's concerns 'lack merit'". The Washington Post. Retrieved April 19, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  87. 87.0 87.1 Rupar, Aaron. "Mick Mulvaney rewrites history, claims Trump never promised to release his tax returns". Vox. Retrieved April 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  88. Itkowitz, Colby. "Mulvaney says Democrats will 'never' see Trump's tax returns". The Washington Post. Retrieved April 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  89. 89.0 89.1 Re, Gregg. "Treasury won't meet House Dems' deadline to provide Trump tax returns, Mnuchin says". Fox News. Retrieved April 11, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  90. Cillizza, Chris. "The secret of why Donald Trump won't release his taxes". CNN.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  91. Haberman, Maggie; Fandos, Nicholas. "Trump Asked That Confirmation of I.R.S. Counsel Be a Priority". The New York Times. Retrieved April 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  92. Bruggeman, Lucien. "Treasury to miss Democrats' deadline for Trump's tax returns, he doubles down: 'I won't do it'". ABC News. Retrieved April 28, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  93. Danner, Chas. "Sarah Sanders: Democrats Aren't 'Smart Enough' to Understand Trump's Tax Returns". New York. Retrieved April 19, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  94. Levenson, Eric. "Sarah Sanders says Congress wouldn't understand Trump's taxes. But 10 members are accountants". CNN. Retrieved April 19, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  95. Farley, Robert. "Trump Wrong About Tax Law". FactCheck.org. Retrieved April 28, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  96. "26 U.S. Code § 6103 - Confidentiality and disclosure of returns and return information". LII / Legal Information Institute.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  97. Jan Wolfe (May 21, 2019). "Trump loses lawsuit challenging subpoena for financial records". Reuters.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  98. 98.0 98.1 Ann E. Marimow, Congress can have access to eight years of Trump's tax records, appeals court orders, Washington Post (November 13, 2019).
  99. Trump v. Mazars USA LLP denial of rehearing en banc, No. 19-5142 (D.C. Cir. Nov. 13, 2019).
  100. 100.0 100.1 Adam Liptak, Supreme Court to Rule on Release of Trump's Financial Records, New York Times (December 13, 2019).
  101. 101.0 101.1 Order List: December 13, 2019, Supreme Court of the United States.
  102. Liptak, Adam (November 18, 2019). "Chief Justice Gives Trump Temporary Reprieve in Financial Records Case". New York Times.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  103. 103.0 103.1 103.2 Stephanie Becker & Kate Sullivan, California Supreme Court says law requiring presidential candidates to turn over tax returns is invalid, CNN (November 21, 2019).
  104. Medina, Jennifer; Karni, Annie (July 30, 2019). "California Requires Trump Tax Returns Under New Election Law". The New York Times. Retrieved July 30, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  105. "California governor signs law that would require Trump to release tax returns". The Guardian. Associated Press. July 30, 2019. Retrieved July 30, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  106. 106.0 106.1 John Myers (September 19, 2019). "Federal judge blocks California law to force disclosure of Trump's tax returns". Los Angeles Times.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  107. John Myers (October 2, 2019). "California will appeal judge's decision to block law requiring Trump's tax returns". Los Angeles Times.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  108. Daniel Tay, 9th Circ. Tosses Suits On Calif.'s Invalidated Tax Return Law, Law360 (December 17, 2019).
  109. Anderson, Bryan (November 21, 2019). "California can't force Donald Trump to release tax returns, state Supreme Court rules". The Sacramento Bee. Retrieved November 21, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  110. Allan Smith (May 8, 2019). "N.Y. state Senate passes bill allowing Congress to get Trump tax returns; The state Senate also passed legislation that would make it easier for the state to prosecute individuals who were pardoned by the president". NBC News. Retrieved May 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  111. Matt Naham (May 8, 2019). "New York Senate Passes Bill to Let Congress See President Trump's State Tax Returns". LawAndCrime.com. Retrieved May 9, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  112. McKinley, Jesse (May 22, 2019). "New York Passes Bill Giving Congress a Way to Get Trump's State Tax Returns". New York Times.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  113. 113.0 113.1 Rashbaum, William K.; Protess, Ben (September 16, 2019). "8 Years of Trump Tax Returns Are Subpoenaed by Manhattan D.A." New York Times. Retrieved September 16, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  114. Toby Ecker (September 23, 2019). "New York prosecutors reject Trump's immunity claim in tax returns case". politico.com. Retrieved September 25, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  115. Larry Neumeister (September 23, 2019). "Prosecutor says Trump wants 'sweeping immunity' in tax fight". Associated Press.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  116. Orden, Erica (October 7, 2019). "Judge dismisses Trump request to keep taxes secret in New York". CNN.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  117. 117.0 117.1 Ann E. Marimow & Jonathan O'Connell, Trump lawyer argues a sitting president would be immune from prosecution even if he were to shoot someone, Washington Post (October 22, 2019).
  118. Lauren Aratani, Trump couldn't be prosecuted if he shot someone on Fifth Avenue, lawyer claims, The Guardian (October 23, 2019).
  119. Oral argument audiorecording and transcript, Trump v. Vance, C-SPAN, October 23, 2019
  120. Case Files: Trump v. Vance (S. Ct. No. 19-635), SCOTUSblog.
  121. 121.0 121.1 121.2 Jeff Stein; Tom Hamburger; Josh Dawsey (October 3, 2019). "IRS whistleblower said to report Treasury political appointee might have tried to interfere in audit of Trump or Pence". The Washington Post.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  122. Naomi Jagoda (October 6, 2019). "Tax-return whistleblower in spotlight amid impeachment fight". The Hill.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>
  123. Jeff Stein; Tom Hamburger; Josh Dawsey; Colin Wilhelm (September 27, 2019). "Democrat Weighs Releasing Complaint About IRS Trump Tax Audit". Bloomberg.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>.
  124. Lorenzo, Aaron (August 20, 2019). "House Democrats say bolsters case for getting Trump's tax returns". Politico. Retrieved October 1, 2019.<templatestyles src="Module:Citation/CS1/styles.css"></templatestyles>