United States v. Jack Carl Ryals

Jack Carl Ryals (“Mr. Ryals”) appeals the district court’s grant of summary judgment in favor of the United States of America (the “Government”) on its complaint, and the court’s dismissal of certain counts, and summary judgment on other counts, of Mr. Ryals’ counterclaim. The Government filed suit against Mr. Ryals seeking to reduce certain tax assessments to judgment. Mr. Ryals filed a ten-count counterclaim for tax refunds.

The lower court granted the Government’s motion for summary judgment, dismissed counts one through eight of the counterclaim on the basis that it did not have subject…