Institute for Resource Management, Inc. v. United States

OPINION

MARGOLIS, Judge.

This tax case is before the court on plaintiffs motion for summary judgment and defendant’s cross-motion for summary judgment. Defendant, the United States, through the Internal Revenue Service (“IRS”), assessed the plaintiff, Institute for Resource Management, Inc. (“IRM”), $11,-086,766.86 for failing to withhold and pay certain federal employment taxes on behalf of its workers. Plaintiff seeks a refund of partial payments of federal employment taxes and moves for summary judgment on the ground that it was exempted from a duty to withhold and pay such taxes by the…