Grand Marina Investors, LLC v. U.S. Internal Revenue Service

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA GRAND MARINA INVESTORS, Plaintiff, v. Case No. 1:23-cv-1676-RCL INTERNAL REVENUE SERVICE, Defendant. MEMORANDUM OPINION After the Internal Revenue Service (“IRS”) audited Plaintiff Grand Marina Investors’ (“Grand Marina”) 2014 partnership tax return, the parties pursued a settlement. Near the end of the negotiations, the IRS abruptly changed its settlement offer and required Grand Marina to accept terms less favorable than what the parties had discussed. Grand Marina later filed two requests pursuant to the Freedom of Information Act…