Case: U.S. District Court Dismisses Taxpayer’s Claims Against IRS Due to Lack of Jurisdiction, Procedural Failures

The U.S. District Court held that it lacked subject matter jurisdiction over the taxpayer’s claims against the IRS and an IRS agent for trespass and interference with business relationships related to a tax investigation, dismissing the case with prejudice. The taxpayer, an individual, filed suit after the IRS questioned her, issued third-party summonses to her bank and associates, and claimed she owed over $9 million in taxes. The court held it lacked jurisdiction because: (1) the taxpayer failed to comply with procedural requirements for petitions to quash summonses under IRC §7609; (2) the Federal Tort Claims Act’s tax exception barred ...