United States Federal Circuit

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Diversified Group Inc. v. US, 2016-1014

In an action brought against the United States, seeking a refund of payments made toward a federal tax penalty which the Internal Revenue Service (IRS) assessed under 26 U.S.C. section 6707 for failure to comply with tax shelter registration requirements under 26 U.S.C. section 6111, the judgment of the U.S. Court of Federal Claims that it lacked jurisdiction over the case is affirmed where plaintiffs Appellants did not comply with the full payment rule.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2016/11/10




  • United States Federal Circuit


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