Nix v. United States
District Court, E.D. Texas
1Opinion of the Court
RODNEY GILSTRAP, UNITED STATES DISTRICT JUDGE
On April 12, 2018, this Court issued a summary order that GRANTED Defendant's Motion to Dismiss Plaintiff's Section 6751 Claims. (Dkt. No. 115.) In that order, the Court announced its intention to issue a written opinion providing "a full explanation and analysis of the Court's ruling announced into the record." (Id. at 2.) Such explanation and analysis is provided herein.
I. BACKGROUND
This is a partner-level refund suit filed under 26 U.S.C. § 6230(c)(3) after three partners, Harold Nix ("Nix"), Charles Patterson ("Patterson"), and Nelson Roach…
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