In Tagore v. IRS, ICAAD files this brief in support of the Appellant, Kawaljeet K. Tagore. ICAAD strongly believes that the District Court erred in granting summary judgment to the United States and in denying Ms. Tagore’s Motion for Summary Judgment. Specifically, ICAAD believes that, in concluding that Ms. Tagore’s kirpan is a “dangerous weapon,” as defined under 18 U.S.C. §930, the District Court ignored record evidence establishing that the kirpan is an article of faith and not a weapon, let alone a “dangerous one.” ICAAD further believes that the District Court erred in holding that Ms. Tagore does not have a sincerely held belief in wearing a kirpan with an edge that is longer than 2.5 inches. The District Court also erred in holding that the United States could not have reasonably accommodated Ms. Tagore’s kirpan without “undue hardship.” As Amicus, ICAAD does not seek to re-litigate the issues, but to provide clarification on these factual issues.

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