Pyramid Petroleum Corp. v. United States

MEMORANDUM ORDER

VINCENT L. BRODERICK, District Judge.

I

Plaintiff Pyramid Petroleum Corp. (“Pyramid”) was a petroleum wholesaler and retailer which had been granted registration pursuant to 26 U.S.C. § 4101(a) by the Internal Revenue Service under regulations designed to avoid evasion of fuel taxes otherwise due under 26 U.S.C. §§ 4081, 4091. Registration may be denied if the Secretary of the Treasury determines that the petitioner is using the registration to postpone or interfere with the collection of taxes or if such denial is “necessary to protect the revenue.” 26 U.S.C. § 4101(c).

Pyramid…