United States v. MacPhail

MEMORANDUM AND ORDER

HOLSCHUH, District Judge.

Plaintiff United States of America asserts a cause of action under 26 U.S.C. § 7405(b) seeking recovery from Defendant Angus MacPhail of an income tax overpayment refund. This matter is currently before the Court on Plaintiffs Motion for Summary Judgment on this claim against Defendant MacPhail. (Docket No. 45). For the reasons below, the Court hereby grants Plaintiffs motion for summary judgment against Defendant Mac-Phail.

I. Background

Initially, Plaintiff asserted claims against both Defendant MacPhail and Sarah Crane for recovery of an erroneous…