Crabtree v. Commissioner

POLOZOLA, District Judge.

John Crabtree filed this suit against the Commissioner of the Internal Revenue Service (“IRS”) and the United States of America (“U.S.”) seeking a declaration that taxpayers are entitled to an administrative hearing prior to final assessment by the IRS in cases brought under 26 U.S.C. § 6672(a).1 2Plaintiff also seeks a return of funds seized by the IRS.

Crabtree served as chairman of the board of First Southern Capital Corpora*258tion, which held a substantial interest in another corporation, Diva, Inc. Crabtree also served as a member of the board of directors of Diva.…