MEMORANDUM OPINION AND ORDER
MILTON I. SHADUR, Senior District Judge.
David Shiner ("Shiner") brings this action pursuant to 26 U.S.C. § 7434 ("Section 7434"), asserting that Bernard Turnoy ("Turnoy") willfully filed a fraudulent income tax information return by transmitting a Form 1099-MISC ("1099") to the Internal Revenue...
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