United States v. Zanfei

MEMORANDUM OPINION AND ORDER

MORTON DENLOW, United States Magistrate Judge.

The United States filed suit against four defendants, including Paradigm Solutions Group, LLC (“Paradigm”), seeking an injunction to prevent the defendants from organizing and selling what the United States terms “abusive tax shelters.” Paradigm answered and counterclaimed, seeking a declaratory judgment that these “tax shelters” are lawful. The United States now seeks to dismiss Paradigm’s counterclaim on three theories: 1) the claim is barred by the doctrine of sovereign immunity; 2) the claim is barred by the tax…