United States of America, Gary O. Booth, Richard D. Roller, and Barbara A. Shandony v. Douglas M. Hart

The United States and three employees of the Internal Revenue Service brought this action for declaratory and injunctive relief against the defendant Douglas M. Hart. Booth is District Director of the Internal Revenue Service for the North Dakota District, Roller is a group manager, and Shandony is an examination and revenue agent. Roller assigned Shandony to audit the income-tax returns of the defendant Hart, who lives in West Fargo, North Dakota.

After the audit was completed, Hart filed in the office of the Register of Deeds for Richland County, North Dakota, documents styled “Common-law…