Ullman v. United States

OPINION AND ORDER

HEWITT, Judge.

Before the court are plaintiffs Two-Count Complaint (Compl.), plaintiffs Motion for Summary Judgment (Pl.’s Mot. or plaintiffs motion), defendant’s Motion to Dismiss (Def.’s Mot. or defendant’s motion), and the responsive briefing on the parties’ respective motions.1 Plaintiff moves for a summary judgment that “the Internal Revenue Service and the U.S. Department of Justice failed to provide, despite repeated requests, the Advice of Chief Counsel,” in contravention of 26 U.S.C. § 6110(j) (2000), and that defendant “intentionally and willfully failed to act in…