Articles Posted in US Court of Appeals for the District of Columbia Circuit

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The DC Circuit affirmed the district court's dismissal of plaintiff's action against the United States under the Taxpayer Bill of Rights, 26 U.S.C. 7433(a). Plaintiff invoked section 7433 to recover damages he claims to have suffered as a result of a mix-up relating to the refund due to him on his 2011 income tax. The court held that section 7433 did not provide a jurisdictional path for plaintiff's action because the statute waives the government's sovereign immunity only for damages suffered in connection with collection of federal taxes, and plaintiff's injury (if any) related to collection of a student loan debt. View "Ivy v. Commissioner" on Justia Law

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Taxpayers who failed to report and pay tax on foreign income filed suit after the IRS denied their applications for the expanded Streamlined Procedures program. The Streamlined Procedures' reduced benefits were counterbalanced by fewer compliance requirements; as relevant here, the Streamlined Procedures participant need not pay any accuracy-based penalty. The DC Circuit affirmed the district court's dismissal of the complaint, holding that the district court was without jurisdiction to resolve taxpayers' claims in light of the jurisdiction-stripping provision contained in the Anti-Injunction Act (AIA), 26 U.S.C. 7421 et seq. View "Maze v. IRS" on Justia Law