McBrady v. United States

MEMORANDUM OPINION AND ORDER

RICHARD H. KYLE, United States District Judge

In this action, Plaintiffs Michael and Valerie McBrady seek a refund of allegedly overpaid income taxes.1 The IRS moves to dismiss for lack of subject-matter, jurisdiction. For the reasons that follow, its Motion will be granted.

BACKGROUND

The McBradys jointly own ImageTrend, a Minnesota corporation that sells data-management software. (Compile 6-7.) ImageTrend is a “subchapter S” corporation (id. ¶ 8), which means it has elected to pass its income through to its shareholders for tax purposes. See https://www.irs.gov/…