United States Ninth Circuit

Bivens relief, whereby government officials are held personally liable for constitutional violations committed under color of government authority, is unavailable for challenges to IRS partnership tax assessment and collection activities. The Internal Revenue Code gives taxpayers meaningful protections against government transgressions in tax assessment and collection.

Appellate Information

• Decided 01/22/2004
• Published 01/22/2004

Judges

Court

• United States Ninth Circuit

Counsel