Payne v. United States

KAZEN, Chief Judge:

The United States appeals the verdict of the district court following a bench trial in which the court found the United States liable for a violation of I.R.C. § 7431. The district court’s findings of fact and conclusions of law are set forth at 91 F.Supp.2d 1014 (S.D.Tex.1999). In sum, the trial *379court determined that IRS Special Agent David Batista made unlawful disclosures of taxpayer Jerry S. Payne’s confidential return information in violation of I.R.C. § 6103, and that these violations were not the result of a “good faith, but erroneous” interpretation of law. I.R.C. §…