Boudali v. IRS

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION MOHAMED BOUDALI, Case No. 19-12848 Plaintiff, SENIOR U. S. DISTRICT JUDGE v. ARTHUR J. TARNOW INTERNAL REVENUE SERVICE, U.S. MAGISTRATE JUDGE DAVID R. GRAND Defendant. / ORDER GRANTING DEFENDANT’S MOTION FOR JUDGMENT ON THE PLEADINGS [17] Plaintiff Mohamed Boudali, a Canadian citizen and resident who works in the U.S., commenced this action against the Internal Revenue Service (“IRS”) on September 30, 2019. Plaintiff claims that the IRS, in violation of Article 25 of the U.S.-Canada Tax Treaty (“Treaty”),…