Legal Opinion
Humphrey v. United States
District Court, N.D. Georgia
Decided December 19, 2011No. Civil Action No. 1:11-CV-01647-SCJPublishedCited by 5 opinions
1Opinion of the Court
ORDER
STEVE C. JONES, District Judge.
THIS MATTER is before the Court on Defendant’s Motion to Dismiss [Doc. No. 4], For reasons given below, the motion is DENIED.
*1302BACKGROUND
Plaintiff is a tax preparer who sold a tax shelter program (the “Shelter”) that the Internal Revenue Service (“IRS”) deemed abusive [Doc. No. 1, pp. 5-7]. Because of Plaintiffs tax shelter sales, the IRS levied a $101,469.00 penalty against her (the “Penalty”), and suspended her from participating in its e-file program for two years (the “Suspension”) [id. at pp. 11-13]. Plaintiff now seeks, inter alia, to have the Penalty…
2Cases cited15 opinions
- Ashcroft v. IqbalSupreme Court of the United States · 2009
- Bell Atlantic Corp. v. TwomblySupreme Court of the United States · 2007
- Flora v. United StatesSupreme Court of the United States · 1960
- R. M. Steele v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Elizabeth L. Henley v. Food and Drug Administration, Department of Health and Human Services Kessler, Dr., Commissioner of Food and Drug United StatesCourt of Appeals for the Second Circuit · 1996
10 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Diversified Group Incorporated v. United StatesUnited States Court of Federal Claims · 2015
- Teresa Tiernan v. United StatesUnited States Court of Federal Claims · 2013
- James Tarpey v. United StatesCourt of Appeals for the Ninth Circuit · 2023
- Diversified Group Incorporated v. United StatesUnited States Court of Federal Claims · 2015
- Diversified Group Incorporated v. United StatesUnited States Court of Federal Claims · 2015