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BORCHARDT v. C.I.R.

No. Civ. 03-5543 RHKAJB.

338 F.Supp.2d 1040 (2004)

Terrence J. BORCHARDT, Plaintiff, v. COMMISSIONER OF INTERNAL REVENUE, Defendant.

United States District Court, D. Minnesota.

October 12, 2004.

Attorney(s) appearing for the Case

Terrence J. Borchardt, Minneapolis, Minnesota, pro se.

Kristin H. Hodges, Trial Attorney, Tax Division, United States Department of Justice, Washington, D.C., for Defendant.

MEMORANDUM OPINION AND ORDER

KYLE, District Judge.

Introduction

Defendant Commissioner of Internal Revenue (the "IRS") assessed monetary penalties against Plaintiff Terrence J. Borchardt for filing frivolous zero-income amended tax returns. After a Collection Due Process Hearing ("CDP Hearing") between Borchardt and an IRS Office of Appeals settlement officer, the IRS issued a Notice of Determination upholding the penalties. Borchardt then sued...

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