Hospital Resource Personnel, Inc. v. United States

BARKETT, Circuit Judge:

In this tax refund action, the United States appeals from a final summary judgment in favor of plaintiff-appellee Hospital Resource Personnel, Inc. (“HRP”). The United States, through the Internal Revenue Service (“IRS”), assessed HRP in excess of $1,144,-000 for failing to withhold and pay certain federal employment taxes on behalf of its workers. HRP filed suit in district court against the United States, seeking a refund of partial payments of federal employment taxes, and a permanent injunction enjoining and restraining the United States from enforcing a lien and…