Wheaton v. United States

OPINION

IRENAS, District Judge:

The current action for injunctive relief stems out of tax penalties assessed by the Internal Revenue Service (“IRS”) against plaintiff for failure to report income allegedly derived from the ownership of certain foreign corporations. As a result of an audit of plaintiff’s personal tax returns from 1979 to 1990, the IRS concluded that plaintiff had a controlling interest in fifteen foreign corporations scattered throughout the Caribbean and South America. Plaintiff admitted ownership of five of these corporations, and reported^all necessary information on Form…