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LARSON v. U.S.

Docket No. 17-503 August Term 2017.

888 F.3d 578 (2018)

John M. LARSON, Plaintiff-Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Second Circuit.

Decided: April 25, 2018.

Attorney(s) appearing for the Case

REED J. HOLLANDER , Nelson Mullins Riley & Scarborough, LLP, Raleigh, NC ( C. Wells Hall, III , Nelson Mullins Riley & Scarborough, LLP, Charlotte, NC; Megan L. Brackney , Kostelanetz & Fink, LLP, New York, NY, on the brief), for Plaintiff-Appellant.

ANDREW E. KRAUSE , Assistant United States Attorney ( Benjamin H. Torrance , Assistant United States Attorney, on the brief) for Geoffrey S. Berman , United States Attorney for the Southern District of New York, for Appellee.

T. Keith Fogg , Director, Harvard Federal Tax Clinic, Jamaica Plain, MA, for Amicus Curiae Legal Services Center of Harvard Law School, in Support of Plaintiff-Appellant.

Before: Parker, Wesley, and Chin, Circuit Judges.

John M. Larson was involved with — and later convicted of crimes related to — the organization of several fraudulent tax shelters. See United States v. Pfaff, 407 Fed. Appx. 506, 508-11 (2d Cir. 2010) (summary order); Pfaff v. United States,

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