Snyder & Associates Acquisitions LLC v. United States

Concurrence by Judge BYBEE

OPINION

CHRISTEN, Circuit Judge:

In 2010, the Internal Revenue Service set a trap to catch people filing for fraudulent tax refunds. The IRS enlisted the assistance of plaintiffs’ tax preparation and refund-advance businesses. It warned that refusal to cooperate would interfere with a federal criminal investigation, it used millions of plaintiffs’ dollars as bait, and it promised to reimburse them for any losses. Plaintiffs cooperated, but the IRS never returned their money. Instead, at the conclusion of the sting operation, the IRS *1155subpoenaed more than 5,000 of…