Kristopher Dreyer v. United States

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA KRISTOPHER DREYER, No. CV 22-1254 PA (KKx) Plaintiff, FINDINGS OF FACT AND

CONCLUSIONS OF LAW

v. UNITED STATES OF AMERICA, Defendant. 15 AND RELATED COUNTERCLAIM 17 Plaintiff Kristopher Dreyer (“Plaintiff” or “Dreyer”) commenced this action on July 19, 2022. Plaintiff’s Complaint alleges a single claim for refund of “overpaid federal taxes” against defendant United States of America (“United States”). (Docket No. 1.) The Complaint alleges that the Internal Revenue Service (“IRS”) erroneously assessed tax penalties against Plaintiff under 26 U.S.C. § 6672 for Riverside Christian Schools’ (“RCS”) failure to pay the trust fund portion of its payroll taxes for the fourth quarter of 2017 and first and second quarters of 2018. Plaintiff paid small portions of the trust fund penalties and then filed claims for refunds with the IRS. The United States filed a Counterclaim in this action, seeking a judgment against Plaintiff for the total amount of…