Bernard M. Barrett, Jr., M.D., and Plastic & Reconstructive Surgeons, P.A. v. United States of America and Internal Revenue Service

OPINION

E. GRADY JOLLY, Circuit Judge:

Dr. Barrett seeks damages against the United States under 26 U.S.C. § 7431 for unlawful disclosures of tax return information during a civil and criminal investigation. The Internal Revenue Service mailed letters to Dr. Barrett’s patients that were designed to determine whether cash payments had been made to him. Dr. Barrett argues that the letters were unnecessary to the IRS’s investigation, and therefore improperly disclosed the fact that he was under investigation, in violation of 26 U.S.C. §§ 7431, 6103. The district court granted summary judgment for…