Carnick v. United States Department of Treasury Internal Revenue Service

OPINION AND ORDER GRANTING DEFENDANT’S MOTION TO AFFIRM DETERMINATION CONCERNING COLLECTION ACTION

ROSEN, District Judge.

I. Introduction

Plaintiff Robert C. Carnick commenced this suit in this Court on September 21, 2005, challenging a determination by the Internal Revenue Service (“IRS”) that he is liable for a Trust Fund Recovery Penalty (“TFRP”) assessed against him for over $45,000.00.

On March 27, 2006, Defendant United States of America filed a motion requesting that the challenged IRS determination be affirmed, on the ground that the IRS appeals officer did not abuse his discretion in…