Snyder & Associates Acquisitions LLC v. United States

Plaintiffs, tax preparation and refund-advance businesses, filed suit against the IRS under the Federal Tort Claims Act (FTCA), alleging several causes of action stemming from plaintiffs' cooperation in a federal criminal investigation. The district court granted the government's motion to dismiss, concluding that the IRS was immune from liability for its conduct under 28 U.S.C. 2680(c). The Ninth Circuit held that section 2680(c) did not confer absolute immunity on the IRS, and, construing the facts in the light most favorable to plaintiffs, the IRS's sting operation did not arise in respect of the assessment or collection of any tax. Accordingly, the panel reversed and remanded for further proceedings. View "Snyder & Associates Acquisitions LLC v. United States" on Justia Law