Legal Opinion
Diversified Group Incorporated v. United States
United States Court of Federal Claims
Decided September 29, 2015No. 14-627TPublishedCited by 7 opinions
1Opinion of the Court
RCFC 12(b)(1); Subject Matter Jurisdiction; Tax Shelter; Full Payment Rule; Penalty; 26 U.S.C. § 6111; 26 U.S.C. § 6707; Aggregate; Divisibility; Abatement; Son-of-BOSS; Option Partnership Strategy; Financial Derivatives Investment Strategy
OPINION AND ORDER
SWEENEY, Judge
Before the court is defendant’s motion to dismiss plaintiffs’ complaint for lack of subject matter jurisdiction. Plaintiffs, James Haber and his company, Diversified Group, Inc. (“DGI”), seek a refund of their partial payment of a federal tax penalty, which the Internal Revenue Service (“IRS” or “Service”) assessed because of…
2Cases cited52 opinions
- Lujan v. Defenders of WildlifeSupreme Court of the United States · 1992
- Steel Co. v. Citizens for a Better EnvironmentSupreme Court of the United States · 1998
- Arbaugh v. Y & H Corp.Supreme Court of the United States · 2006
- McNutt v. General Motors Acceptance Corp.Supreme Court of the United States · 1936
- United States v. TestanSupreme Court of the United States · 1976
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3Cited by7 opinions
- Haber v. United StatesCourt of Appeals for the Second Circuit · 2016
- Diversified Group Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2016
- James Tarpey v. United StatesCourt of Appeals for the Ninth Circuit · 2023
- Board of Supervisors of Issaquena County, Mississippi v. United StatesUnited States Court of Federal Claims · 2024
- Gaynor v. United StatesUnited States Court of Federal Claims · 2020
2 more not listed; retrieve them via the Exa API.