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IVY v. C.I.R.

No. 16-5242.

877 F.3d 1048 (2017)

Reginald L. IVY, Appellant v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided December 19, 2017.

Attorney(s) appearing for the Case

Travis Crum , Washington, DC, appointed by the court, argued the cause as amicus curiae in support of appellant. With him on the briefs was Brian D. Netter , Washington, DC.

Reginald L. Ivy, pro se, filed the briefs for appellant.

Clint A. Carpenter , Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Joan I. Oppenheimer , Attorney.

Before: Henderson, Circuit Judge, and Williams and Ginsburg, Senior Circuit Judges.

A provision of the Taxpayer Bill of Rights, 26 U.S.C. § 7433(a), provides for a civil action against the United States if a taxpayer suffers damages as a result of reckless, negligent or intentional disregard of the Code or regulations "in connection with any collection of Federal tax" with respect to that taxpayer...

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