Siddiqui v. United States

ALARCÓN, Circuit Judge.

Zariq and Greta Siddiqui, Joseph, Richard and Elizabeth Vullo, and Vullo, Siddi-qui & Associates, Ltd. (“VSA”) (collectively, “Appellants”) appeal from the district court’s limitation of its award under 26 U.S.C. § 7431 to a total of $6,000 in statutory damages, and the denial of punitive damages for the unauthorized disclosure of income tax return information. We affirm because we conclude that only one act of disclosure occurred. We also hold that under § 7431 punitive damages are precluded absent proof of actual damages.

I

On June 26, 1997, agents of the Internal…