1. There are material misrepresentations by the plantiff and by their counsel. The entire premise is that Moore shouldn't have to pay taxes without realized income, and he has no control over when his Indian holdings would realize profits -- except he owns 11 percent of the company and served on the board of directors for five years[2].
2. One of the attorneys on the case is also a WSJ editorialist who frequently interviews and coauthors articles with Justice Alito.
3. Alito has refused to recuse himself from the case (IMO on dubious grounds), and now has to really bend over backwards to ignore the perjury in #1.
4. There was no reason to grant this case cert, as it had no circuit split.
5. If overruled, it would immediately unleash a trillion dollar amount of chaos on the US tax code at a point in which Congress frankly is not equipped to govern.
6. The amount in dispute is around 15,000USD. I promise you the lawyers cost more than that. What the Tax Foundation isn't saying: plaintiffs want the supreme court to preemptively strike down the possiblity of a federal wealth tax.
[1]: https://slate.com/news-and-politics/2023/12/sam-alito-moore-...
[2]: https://www.taxnotes.com/featured-analysis/moore-part-4-moor...