Johnson v. United States

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 10 RICHARD L. JOHNSON and GAIL D. No. 2:19-cv-01561-TLN-JDP

JOHNSON,

12 Plaintiffs, ORDER v.

UNITED STATES OF AMERICA,

15 Defendant. 16 This matter is before the Court on Defendant United States of America’s (the “Government”) Motion for Reconsideration. (ECF No. 23.) Plaintiffs Richard L. Johnson and Gail D. Johnson (collectively, “Plaintiffs”) filed an opposition. (ECF No. 30.) The Government filed a reply. (ECF No. 32.) For the reasons set forth below, the Court GRANTS the Government’s Motion for Reconsideration. (ECF No. 23.) /// /// /// /// /// /// /// I. FACTUAL AND PROCEDURAL BACKGROUND The Court need not recount the background facts of the instant case as they are set forth fully in its September 30, 2021 Order. (ECF No. 20.) On August 12, 2019, Plaintiffs filed the instant action, alleging two claims in which Plaintiffs sought $4,761 for the 2009 tax year (which represents offsets from tax years 2013 and 2014) and…