Johnson v. United States

ORDER GRANTING DEFENDANT’S CROSS-MOTION FOR SUMMARY JUDGMENT AND DENYING PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT

HACKETT, District Judge.

In this lawsuit, plaintiffs are seeking relief from a penalty imposed by the Internal Revenue Service for allegedly promoting an abusive tax shelter. Plaintiff Cooper has moved for summary judgment on the issue of the appropriate amount of the penalty imposed and defendant has filed a cross-motion. Cooper is the sole moving plaintiff because his case is the only one that involves no issue of material fact and the remaining claims have been stayed pending…