COHEN v. INTERNAL REVENUE SERVICE

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY MARTIN L. COHEN, Plaintiff, Civ. No. 2:19-00764 (WJM) v. OPINION INTERNAL REVENUE SERVICE and UNKNOWN CO-CONSPIRATOR, Defendants. WILLIAM J. MARTINI, U.S.D.J.: The United States of America, as the real party in interest and in place of the named Defendants, Internal Revenue Service (“IRS”) and an unknown co-conspirator, moves for dismissal pursuant to Rules 12(b)(1) and 12(b)(6) on the grounds that sovereign immunity bars suit and that Plaintiff’s Amended Complaint fails to state a claim upon which relief may be granted. For the…