Merrick v. United States

OPINION

SMITH, Chief Judge.

Plaintiff, Robert Merrick, brings suit against the Internal Revenue Service (IRS) demanding over $1 million in commissions and $1 million in damages, arguing that the IRS breached a contract it made with him pursuant to Section 7623 of the Internal Revenue Code. This provision allows IRS officials to give monetary rewards for information helpful in discovering unlawful tax practices. Defendant moves for partial summary judgment, arguing that IRS Publication 733 limits the amount of the reward to $50,000 for information about related taxpayers, and that the taxpayers…