Loofbourrow v. Commissioner of Internal Revenue Service

MEMORANDUM AND ORDER

CRONE, United States Magistrate Judge.

Pending before the court is Defendant United States’ Motion to Dismiss or for Summary Judgment (# 12). The United States, on behalf of the Commissioner of the Internal Revenue Service (“IRS”), seeks dismissal or summary judgment on Plaintiff Travis S. Loofbourrow’s (“Loof-bourrow”) Petition for Reversal of Penalty Determination (# 1). Having reviewed the pending motion, the submissions of the parties, the pleadings, and the applicable law, the court is of the opinion that dismissal and/or summary judgment is warranted.

I. Background

On…