United States Second Circuit

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Larson v. US, 17-503

Affirming a district court judgment dismissing a complaint in a suit seeking the review of an Internal Revenue Service assessment of $160 million in penalties against a tax shelter guru who raised statutory and constitutional grounds, but his theories didn't hold water and the district court's determination that they lacked subject matter jurisdiction and he had failed to state a claim were not improper and the penalties did not impact due process, the Administrative Procedure Act, and the Eighth Amendment.

Appellate Information

  • Decided
  • Published 2018/04/25




  • United States Second Circuit