Le Doux v. United States

MEMORANDUM OPINION AND ORDER

BROWNING, District Judge.

THIS MATTER comes before the Court on the United States’ Motion for Summary Judgment, filed August 22, 2003 (Doc. 10). The Court held a hearing on this motion on December 16, 2004. The primary issues are: (i) whether the Court should review the issues that Plaintiff Vera Le Doux’ IRS Appeals hearing raises under an abuse of discretion or de novo standard; (ii) whether Le Doux’ zero tax returns with attachments that challenge the IRS’ authority to collect income tax constitute frivolous tax returns under 26 U.S.C. § 6702; and (in) whether…