Anti-Injunction Act Halts Appraiser’s Valuation Penalties Case

The Anti-Injunction Act applies to a suit brought by a real estate appraiser over IRS penalties connected to his property assessments.

The US District Court for D.C. granted an IRS motion to dismiss a case brought by William Summerour, who is a real estate appraiser working in conservation easements, citing lack of jurisdiction under the Anti-Injunction Act. Summerour sued in August 2023 after the IRS audited three conservation easement properties he’d provided assessments for and levied him $187,500 in penalties after determining he’d grossly misvalued each property.

The government had argued that the assessed penalty he’s suing over, outlined in ...