Miller v. United States

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER

PATEL, District Judge.-

This matter arises out of an international withholding tax audit conducted by the Internal Revenue Service (“IRS”) under 26 U.S.C. § 1441 against Albert- Miller as withholding agent for A-Alphatronics, Inc.. The IRS recommended withholding tax liability in excess of $10,000,000 and additional penalties in excess of $6,000,000.

*717BACKGROUND

This case presents issues involving sections 7432 and 7433 of the Internal Revenue Code, which were enacted as part of the so-called “Taxpayer Bill of Rights” in the Technicál and…